Comments EPA 11.8.11

J.C.


Thank you for the opportunity to communicate our concerns. I hope this is the beginning of our being in regular contact. We need an open channel as the situation on the ground is rapidly changing. The situation is actually out of control, and no government agency has a handle on it.

Congress is not moving on regulations and our administration has no articulate energy or environmental policy. Policies are being made lease by lease. What is in a lease (or what a lease lacks) is what is happening on the ground. We need the PA EPA to be a permanent voice, open and available.

The EPA needs to work at the lease level by promulgating protective lease provisions. This would give individual landowners rights to control mirco-situations and environmental needs that could never be part of national policy, such as herbicide usage, control of light, sound and vibration pollution, control of truck access, street widening and perhaps most importantly defined penalties and access to the courts. Then, instead of the EPA being sued for not enforcing regulations or having to depend on bureaucracy, a strong lease gives the citizen real power.

The EPA must make the PA DEP do its job. Currently the government of PA is in the hands of the gas industry as are local politicians who take money from gas companies to support their campaigns. There is little hope in this political environment for environmental protections. However, the EPA can make rules that landowners can include in their leases bringing things to the level where protection is required – the landowner’s front yard.

It is vital to note, this situation is unlike concentrated industrial pollution. What we have is widely dispersed pollution with varying degrees of seriousness occurring over an extended period of time. The EPA needs to be on the ground with the people to appreciate the impacts.

I propose the creation of a PA EPA office in Montrose, better yet, in each county where drilling occurs. This office would serve as the people’s voice locally while carrying the message reliably to Washington.


Here are some of the issues we face as a result of gas drilling in NE PA:


Unmitigated methane migration is not often monitored and often times not discovered. Migration may go on indefinitely effecting air, water and soil quality.

These topics are all major concerns and are negative impacts created by the industry’s practices. Cumulative impacts are immediate, long term and are growing. What is EPA’s plan? We need regulations, monitoring, follow up and meaningful enforcement.

If the industry will not be stopped until proven safe, can it be slowed enough so regulatory agencies can properly keep pace? As the EPA expects, PA will have 100,000 wells drilled. We are currently at 2%, approx. 2000 wells. 4% of wells leak toxic materials from the onset. And this is allowed? What do you recommend we do to maintain our health in the face of direct, continual pollution? What will the EPA do to support and protect public health and welfare?

Current natural gas drilling techniques cause cytotoxins, genotoxins and carcinogens to be released into the air (and often water and land) during every stage of production. In Colorado, West Virginia and Wyoming (where air in drilling areas is as polluted as in LA), as a result of the same practices occurring in PA, there are multitudes of documented illnesses and cancer clusters due directly to these emissions. We need you to monitor, regulate and hold industry accountable, day in and day out. What will you do? How can we be of assistance?

The gas industry’s impact on agriculture is far reaching. Farmers not only loose productive acreage due to pads, stations and access roads but organic operators loose additional acreage due to the installation of required buffer zones to protect organic crops from potential contamination. Farmers are selling their animals and going out of business with aquifer ruination. When a pad was built in an organic farmer’s field near his dairy barn, he lost so much of his pastureland that he wasn’t able to continue with his organic certification, as he could no longer meet the NOP’s pasture rule. Many farmers are concerned about making financial improvements on their farms. As of 2011, we have put a hold on capital infusions on our own farm, as we don’t know if the inputs can be recouped. If our environment is destroyed where will that leave us, the 4th, 5th, 6th and 7th generations now living there?

When I was in college I lived just outside LA. There we didn’t expect clean air or clean water – we had LA. Here in rural PA what we have is a clean environment. When that’s gone, what will be left?

These are fundamental social and environmental justice issues. I implore you to protect us, and the environment.