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Food & Water Watch works to ensure the food and water we consume is safe, accessible and sustainablyproduced. So we can all enjoy and trust in what we eat and drink, we help people take charge of where their food
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About Food & Water Watch
Copyright September 2014 by Food & Water Watch.All rights reserved.
This report can be viewed or downloaded at foodandwaterwatch.org.
8/11/2019 The Urgent Case for a Ban on Fracking
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The Urgent Case for a Ban on Fracking
I
n many ways, racking is he environmenal issue o our ime. Is an issue
ha ouches on every aspec o our lives he waer we drink, he air we
breahe, he healh o our communiies and i is also impacing he global
climae on which we all depend. I pis he larges corporae ineress big oiland gas companies and he poliical leaders who suppor hem agains people
and he environmen in a long-erm sruggle or survival. I is an issue ha has
capivaed he hears and minds o hundreds o housands o people across
he Unied Saes and across he globe. And i is an area in which, despie he
massive resources o he Frackopoly he cabal o oil and gas ineress promoing his pracice we as
a movemen are making remendous srides as our collecive power coninues o grow.
Food & Waer Wach is proud o work shoulder o shoulder wih communiies across he counry and
across he world in his effor. Wih mouning evidence abou he harms o racking and he immediacy
o he impending climae crisis, his repor lays ou he urgen case or a ban on racking.
In 2009, we became alarmed abou he hrea ha hydraulic racuring (racking) posed o our waer
resources. Communiies around he counry were already raising he alarm abou he ill effecs ha
racking was having, rom increased ruck raffic o spills and even ap waer ha could be li on ire
hanks o mehane leaks rom racking wells ino waer sources.
Meanwhile, many naional environmenal groups were ouing naural gas as a bridge uel a beter
means o producing energy rom ossil uels han coal, a source ha everyone knew we had o move
away rom urgenly o reduce he carbon emissions ha were heaing he plane a a dangerous rae.
Communiies ha were already eeling he effecs o he echnology, or ha were ighing he coming
wave o racking, el berayed ha he place hey lived could become one o he sacriicial zones wih
many environmenaliss blessing. Over he nex ew years, scieniic evidence would moun ha no
only is racking no climae riendly, bu i has he poenial o unleash massive amouns o mehaneha will conribue o climae disaser.
So we began our work on racking wih Not So Fast, Natural Gas, our repor ha raised serious ques-
ions abou racking saey and he naural gas rush being promoed by indusry and governmen. Tha
repor, released in 2010, called or a series o regulaory reorms, bu he evidence coninued o moun.
The nex year, afer looking a even greaer evidence o he inheren problems wih racking, and real-
izing how inadequaely he saes were regulaing he oil and gas indusry and enorcing hose regula-
ions, Food & Waer Wach became he irs naional organizaion o call or a complee ban on racking,
and we released he repor The Case for a Ban on Gas Fracking.
Since he release o ha repor in 2011, more han 150 addiional sudies have been conduced on a range
o issues rom waer polluion o climae change, air polluion o earhquakes reinorcing he caseha racking is simply oo unsae o pursue. In he ace o such sudies, and ollowing he lead o grass-
roos organizaions ha have been a he oreron o his movemen, a consensus is emerging among
hose working agains racking ha a ban is he only soluion. No only are ederal and sae officials no
regulaing he pracice o racking, i is so dangerous and he poenial so grea ha i canno be regu-
laed, even i here were he poliical will. This is why Americans Agains Fracking, a naional coaliion
ha Food & Waer Wach iniiaed in 2012, has coninued o atrac suppor. The coaliion now has over
275 organizaions a he naional, sae and local levels unied in calling or a ban on racking and relaed
aciviies.
Letter from Wenonah HauterExecutive Director, Food & Water Watch
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ii Food & Water Watch foodandwaterwatch.org
As his repor lays ou, here is mouning evidence ha racking is inherenly unsae. Evidence builds
ha racking conaminaes waer, pollues air, hreaens public healh, causes earhquakes, harms local
economies and decreases propery values.
And mos criically or he survival o he plane, racking exacerbaes and acceleraes climae change.
We are acing a climae crisis ha is already having devasaing impacs and ha is projeced o escalae
o caasrophic levels i we do no ac now. Presiden Barack Obama came ino office ouing racked gas
as a bridge uel, ye mouning evidence suggess ha raher han serving as a bridge o a renewable
energy uure, is a bridge o a climae crisis.While he environmenal, public healh and ood movemens have looked a mouning evidence and
rejeced racked gas and oil, Presiden Obama and his adminisraion have aggressively promoed
naural gas and domesic oil as a criical par o he Unied Saes energy uure. Presiden Obama
repeaedly ous domesic gas producion and has said ha we should srenghen our posiion as he
op naural gas producer [I] no only can provide sae, cheap power, bu i can also help reduce our
carbon emissions. His Energy Secreary Ernes Moniz has close indusry ies and has claimed ha he
has no seen any evidence o racking per se conaminaing groundwaer and ha he issues in erms
o he environmenal ooprin o hydraulic racuring are manageable.
Obamas Inerior Secreary Sally Jewell has bragged abou racking wells in her prior career in he
indusry and has, despie radical changes in how racking is done, called i a echnique [ha] hasbeen around or decades, and even implied ha direcional drilling and racking can resul in a sofer
ooprin on he land. And he person charged wih proecing communiies waer, Environmenal
Proecion Agency Adminisraor Gina McCarhy, has claimed Theres nohing inherenly dangerous
in racking ha sound engineering pracices can accomplish, all while he EPA has ignored or buried
indings ha racking has conaminaed waer in Texas, Wyoming and Pennsylvania. Mos recenly,
he adminisraion and several legislaors have been pushing expors o liqueied naural gas abroad o
counries where i will ech he highes price, soking already massive oil and gas indusry prois a he
expense o our rural communiies, our waer and our climae.
This suppor or racking a he highes levels has caused unnecessary conusion and creaed poliical
space or oherwise-concerned environmenally leaning governors o pursue racking. In Caliornia,
Governor Jerry Brown has been supporing racking despie his saed desire o igh climae change. In
Maryland, Governor Marin OMalley has pursued a more cauious approach, bu sill has spoken avor-
ably abou uure producion and recenly reerred o naural gas as a bridge uel. In New York, Governor
Andrew Cuomo has no lifed a popular de factosaewide moraorium on racking due o signiican
public pressure, bu has also no moved o adop a permanen ban. Ciing Presiden Obamas suppor or
racking, he indusry has criicized Cuomo.
Despie wha Presiden Obama and his adminisraion claim, here have now been over 150 sudies on
racking and is impacs ha raise concerns abou he risks and dangers o racking and highligh how
litle we know abou is long-erm effecs on healh and our limied reshwaer supplies. Is ime or
Presiden Obama and oher decision makers o look a he acs and hink abou heir legacy. How do
hey wan o be remembered? Wha do hey wan he world o look like 20, 50 and 100 years rom now?
We irs made he case or a ban on racking in 2011, bu his new repor shows ha here is an urgen
case or a ban. The evidence is in, and i is clear and overwhelming. Fracking is inherenly unsae, canno
be regulaed and should be banned. Insead, we should ransiion aggressively o a renewable and
efficien energy sysem.
8/11/2019 The Urgent Case for a Ban on Fracking
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The Urgent Case for a Ban on Fracking 1
Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Water and Land Impacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Water consumption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Impacts on surface waters, forests and soils . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Aquifer contamination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Mehane and oher hydrocarbon gases . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Hydrocarbon gases in aquiers as a sign o more problems o come . . . . . . . . . . 10
Earthquakes, Lightning Strikes and Exploding Trains . . . . . . . . . . . . . . . . . . 13
Air and Climate Impacts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Silica dust. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15
Byproducts from combustion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15
The pollutants that oil and gas companies bring to the surface . . . . . . . . . . . . . . . . 16
Emissions are larger han officials esimae . . . . . . . . . . . . . . . . . . . . . . . . 17
Naural gas dependence causes more global warming han hough. . . . . . . . . . .18
Public Health, Economic and Social Impacts . . . . . . . . . . . . . . . . . . . . . . . 20
Ban Fracking and Usher in a Safe and Sustainable Energy Future . . . . . . . . . . . 22
TABLE OF CONTENTS
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2 Food & Water Watch foodandwaterwatch.org
Executive SummaryRegarding he uure o he U.S. energy sysem, he erm
racking has come o mean more han jus he speciic
process o injecing large volumes o various mixes o
waer, sand and chemicals deep underground, a exreme
pressure, o creae racures in argeed rock ormaions
all so ighly held oil and gas migh low.
We now use he erm racking o represen all ha hisspeciic process o hydraulic racuring enails. Allowing
more racking means ha oil and gas companies will
coninue o:
Fragment forests and mar landscapeswih new
roads, well sies, wase pis and pipelines;
Compete with farmers for local water supplies
while consuming millions o gallons o waer or each
racked well;
Produce massive volumes of toxic and even
radioactive waste, he disposal o which is causingearhquakes and puting a risk drinking waer
resources;
Cause thousands of accidents, leaks and spills
each year ha hreaen public healh and saey and
pu a risk rivers, sreams, shallow aquiers and arms;
Pump hazardous pollutants into the air, a he
expense o local communiies, amilies and arms;
Turn homes into explosive hazardsby conami-
naing waer wells wih mehane and oher lammable
gases; Put vital aquifers at risk for generationsby
creaing new pahways or he poenial low o
conaminans over he coming years and decades;
Destabilize the climate on which we all depend
wih emissions o carbon dioxide and mehane and by
locking in uure climae polluion wih new oil and
gas inrasrucure projecs; and
Disrupt local communities, wih broad physical
and menal healh consequences, increased demand
on emergency and oher social services, damage o
public roads, declines in propery value, increased
crime, and losses el in esablished secors o local
economies.
In 2011, Food & Waer Wach called or a ban on racking
because o he signiican risks and harms ha accom-
pany he pracice. Now, over hree years laer, numerous
peer-reviewed sudies published in scieniic, legal and
policy journals have expanded wha is known and clari-
ied wha remains unknown abou he environmenal,
public healh and socioeconomic impacs ha sem rom
racking. In his repor, Food & Waer Wach reviews he
science and renews is call or a ban.
We ind ha he open quesions amoun o unaccepable
risk, and ha he harms are cerain. Sringen regulaions,
even i pu in place and even i adequaely enorced, would
no make racking sae. Municipal bans, moraoria and
zoning laws are being passed o ry o proec communi-
ies across he counry, bu ederal and sae level acion is
necessary o reverse he spread o racking.
The only pah o a susainable economic uure is o
rebuild he U.S. energy sysem and local economies
around sae energy soluions: efficiency, conservaionand renewable resources. Fracking akes us in he wrong
direcion.
PHOTO BY HENDRIK VOS
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The Urgent Case for a Ban on Fracking 3
IntroductionHydraulic racuring allows oil and gas companies o arge
underground layers o rock ha hold oil and gas, bu ha
do no readily allow he oil and gas o low up a well.
Drilling hrough hese rock ormaions, hen injecing a
blend o waer, sand and chemicals a exreme pressure,
creaes racures propped open by he sand, exposing
oherwise ighly held oil and gas and allowing i o low.
In response o declines in convenional producion, and o
he lack o access o many inernaional sources o oil and
gas,1companies are now racking in he Unied Saes on
an unprecedened scale. (See Box 1.) Acids are also being
injeced, paricularly in Caliornia and perhaps increasingly
in Florida, o ea away new pahways or oil and gas o
low, wih or wihou creaing new racures.2
The oil and gas indusry enjoys avored saus under
he law and an enrenched posiion in U.S. poliics,
economics and insiuions. This creaes an ineria ha
imperils curren and uure generaions, and endangers our
economy, as we ace he consequences o global warming
and he legacy o he indusrys polluion.
The curren saus quo a he ederal level, and in many
saes, is o encourage as much drilling and racking or
oil and gas as possible. Increased poliical and legislaive
gridlock in Washingon, D.C. has helped o mainain his
saus quo.14Those wih large sakes in oil and gas produc-
ion a angle o oil and gas companies, engineering and
consrucion irms, environmenal consulancies, rade
associaions, public relaions and markeing irms, inancialinsiuions and large individual invesors sand o proi
rom his saus quo.
Revolving doors and srucural ies beween he indusry
and sae and ederal agencies,15academic research groups
ha ac as saellie indusry labs and hink anks,16and
indusry conrol o access o daa and sies,17as well as
echnical experise,18all illusrae he exen o he oil and
gas indusrys capure o U.S. energy policy. The oil and
gas indusrys inluence is releced in he exempions ha
i enjoys in key provisions o all o he landmark environ-menal laws, including he Clean Air Ac, he Sae Drinking
Waer Ac, he Clean Waer Ac and laws regulaing
hazardous wases.19
Over a rillion dollars in sunk coss in inrasrucure
avors he saus quo o dependence on he oil and gas
indusry, serving as a barrier o he remaking o he U.S.
energy sysem.20The oil and gas indusry receives abou $4
billion each year in direc axpayer-unded subsidies.21The
Box 1 The scale of frackingTo hydraulically fracture a modern onshore oil or gas well,
batches of hundreds of thousands of gallons of water,
tons of sand and thousands of gallons of chemicals get
injected repeatedly, typically in tens of stages along a
mile-plus long, several-inches-wide tunnel, or borehole,
that runs laterally through a targeted rock formation
thousands of feet below ground. Oil and gas companiesare now doing this more than 10,000 times each year
in the United States to extract so-called shale gas, tight
gas and tight oil.3
that the companies inject, to eat away pathways for oil
fracking is largely unknown, but the practice is clearly on
the rise and a focus of the oil and gas industry.4
In 2012, the U.S. Energy Information Administration
estimated that bringing the projected amounts of techni-
cally recoverable as if recovering something lost
shale gas and tight oil into production would requiredrilling and fracking over 630,000 new onshore wells.5If
this happens, many thousands of the wells envisioned
are likely to have cementing and casing issues from the
outset, and all of them will age and degrade over subse-
quent years and decades, putting at risk underground
sources of drinking water.6Given that initial fractures
release just a small fraction of the oil or gas held in
targeted source rocks, industry will also seek to re-frac-
ture many thousands of these wells to try to reverse the
typically rapid declines in production as they age.7
A 2013 analysis from the Wall Street Journalfound that
over 15 million Americans are living within one mile
of a well drilled after the year 2000, when large-scale
hydraulic fracturing operations began.8Many more live
alongside other polluting infrastructure that supports
oil and gas production, including processing plants,
-
nities have passed actions in opposition to drilling,
fracking and supporting infrastructure.9
Oil and gas companies have piled up over $100 billion in
debt, in large part to support drilling and fracking and
related infrastructure.10Data from the major publicly
listed oil and gas companies show that from 2008 to2012, collective capital spending increased by about 32
percent, while, at the same time, oil production fell by
about 9 percent.11Evidently the industry is banking that
increased drilling and fracking into the future, coupled
with increased oil and natural gas exports, will translate
rise.12Industrys bubble will burst, not least because
societys systematic dependence on fossil fuels is posing
an existential threat by destabilizing our climate.13
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4 Food & Water Watch foodandwaterwatch.org
Sierra Club and Oil Change Inernaional recenly calcu-
laed ha subsidies o he ossil uel indusry in 2009 and
2010 amouned o a 59 o 1 reurn on he money ha he
indusry spen hose years on lobbying and on inancing
poliical campaigns.22
In his repor, Food & Waer Wach summarizes recen
scieniic lieraure on he waer polluion, landscape
changes, air polluion, climae polluion and wase
disposal problems brough on by drilling and racking or
oil and gas. These impacs are due in large par o he
oxic naure and pervasive spread o he chemical pollu-
ans ha he indusry brings o he surace. (See Box
2.) Recen research urher reveals how hese and oher
impacs collecively damage public healh and disrup
communiies.
Box 2 The pollutants that the oil and gas industry brings to the surfaceNatural gas, natural gas liquids, crude oil, drilling muds and produced water are innocuous-sounding terms that
conceal the nature of all that the oil and gas industry brings to the surface.
-
carbons is called crude oil when the bulk of the hydrogen and carbon atoms that make up the mix are bound together
in large molecules, and the mix is liquid when it reaches the surface.23The term natural gas liquids refers to a variety of
2
6
3
8), butanes
4
10) and other lightweight hydrocarbon chains that happen to be somewhat wet to the touch at moderate temper-
atures and pressures.24The term natural gas is used broadly to refer to various gases that are made up primarily of
4),25a potent greenhouse gas26and a primary driver of global warming.27But drilling and fracking bringsmuch more to the surface than just these hydrocarbons.
chemical compositions vary in time and vary from well to well, but are otherwise not well characterized.28
Many of the hydrocarbons brought to the surface are hazardous pollutants, including volatile organic compounds
aromatic hydrocarbons.29
with ancient salt waters, or brines.30
sodium31 32), and radioactive material
33
Finally, oil and gas companies bring to the surface various amounts of the chemicals used in fracking, and byproducts
from reactions involving these chemicals.34Given trade-secret protections in federal and state laws, and otherwise
often even to the company doing the injecting.35
36
hydrochloric acids are also commonly used to clear out new pathways for oil and gas
37
With the exception of the fracking chemicals and the byproducts of any fracking
chemical reactions, all of the above chemical pollutants had long been safely seques-
tered and immobilized, deep underground. Now, drilling and fracking brings these
pollutants to the surface at baseline levels that risk human health and environmental
damage through water, soil, air and climate pollution. Then there are the greater-than-
baseline levels of contamination: the accidents, leaks, spills and explosions that are
that they can be cleaned up.
The liquids, sludge and solids that remain from what the industry does not leak into
the air, spill on the ground, burn or otherwise use, are adding up to create waste
disposal problems. This pollution is part and parcel of the current all-of-the-above
approach to U.S. energy policy. All of the above pollutants need to stay underground.
Mud pit on a Bakken shaledrilling site.
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The Urgent Case for a Ban on Fracking 5
Pu simply, widespread drilling and racking or oil and
gas is inherenly unsae and erribly shorsighed. This
repor explains why i is ime or a ban. The oil and gas
indusrys corruping inluence on policy and govern-
men hreaens o coninue he harm, and o coninue o
supplan proven and sae soluions or meeing energy
needs.
Water and Land ImpactsThe oil and gas indusrys capure o U.S. energy policy
has colored several high-proile invesigaions o aquier
conaminaion in he afermah o drilling and racking,
namely in Pavillion, Wyoming, in Dimock, Pennsylvania,
and in Parker Couny, Texas.
In December 2011, he U.S. Environmenal Proecion
Agency (EPA) published a draf scieniic repor on
groundwaer conaminaion in Pavillion, Wyoming, saing
ha wase pis likely conaminaed shallow groundwaer38
and ha daa on chemicals deeced in a deeper moni-oring well indicaes likely impac o ground waer ha
can be explained by hydraulic racuring.39The draf
repor called or more monioring o wells o make he
indings o he repor more deiniive.40In he ace o
exreme pressure rom he indusry and rom indusry
advocaes in Congress, however, he EPA decided in
2013 o abandon inalizing he repor.41Insead, he EPA
deerred i o he Sae o Wyoming, which will rely on he
company implicaed in he case o und a new invesiga-
ion.42While he EPA claims ha i sill sands behind
is work and daa,43
he rerea was widely repored as avicory or he indusry.44
In 2012, he EPA similarly rereaed rom is invesigaion
o waer conaminaion cases in Dimock, Pennsylvania,45
which he saes environmenal agency had deermined
were due o drilling aciviies.46The EPA had ound
conaminans in several o he waer wells in quesion, bu
simply saed ha he residens have now or will have
heir own reamen sysems ha can reduce concenra-
ions o hose hazardous subsances o accepable levels
a he ap.47The EPA ailed o evaluae he reasons or
he conaminaion, again leaving he public wih he alse
impression ha affeced residens claims o conamina-
ion had no meri.48
In December 2014, he EPA will issue a draf o a muli-
year sudy on he poenial impacs o racking on
drinking waer resources. In his sudy, he agency is
relying heavily on volunary cooperaion rom he oil
and gas indusry or daa and experise. This reliance on
indusry parly explains he EPAs rerea on he hird
high-proile case o conaminaion linked o drilling and
racking, in Parker Couny, Texas.49According o he EPAs
Inspecor General, a primary reason ha he agency
wihdrew is emergency order agains he company doinghe drilling and racking was ha he company agreed
o paricipae in he EPAs ongoing sudy.50This episode,
in paricular, highlighs how he indusrys conrol over
daa and experise shapes he science and invesigaions
carried ou on behal o he public.
The residens o Parker Couny, Dimock and Pavillion
wen o he EPA because hey did no eel ha heir
respecive saes were being responsive o heir concerns.
Texas, Pennsylvania and Wyoming each have long hiso-
ries o promoing oil and gas developmen, in he name o
prevening wase o oil and gas reserves,51and are paryo inersae resoluions o encourage shale gas exracion
and expansion o naural gas inrasrucure.52The EPAs
unwillingness o complee invesigaions o hese hree
landmark cases o drinking waer conaminaion means
ha he affeced residens have nowhere else o urn.
Generally, he risks and impacs o waer resources
include he indusrys compeiion or waer, land and
surace waer polluion, and aquier conaminaion.53
Water consumptionAffordable access o clean waer is a public healh issue,
and a human righ. Public waer sysems already ace
major challenges ha will be exacerbaed by global
warming, in he orm o locally severe droughs, exreme
sorms and oherwise alered rainall, snowall and
snowmel paterns.54Over a cenury o climae pollu-
ion semming rom he oil and gas indusry conribues
signiicanly o his warming.55
Land is cleared for drilling and fracking in Pennsylvania.
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6 Food & Water Watch foodandwaterwatch.org
Now, wih widespread drilling and racking, he oil and
gas indusry is no jus adding more climae polluion, i
is adding signiican demand or resh waer in already
waer-sressed regions o he counry. Even worse, i is
leaving a legacy o waer polluion and landscape disur-
bance.
Waer use per well varies by region, bu companies
ypically require abou 5 million gallons o waer o drilland rack a single shale gas or igh oil well. 56Some
horizonal wells in he Eagle Ford shale play in Texas have
been racked wih more han 13 million gallons each.57
Esimaes vary as o how much injeced luid reurns,
rom beween 5 and 50 percen.58In he Marcellus region,
beween he irs sage o racking and he ime he
new well is pu ino producion, he liquid ha lows up
he well amouns o only abou 5 percen o he volume
injeced.59Thus, almos all o he waer used in racking
luids is no available or reuse, and is underground
indeiniely.Oil and gas advocaes claim ha heir waer use is low
relaive o overall waer use, bu saisics ha average
over large regions are decepive. Frackings use o waer
can be inensive, happening all in a local hospo or
drilling and racking and all a once or each new well.
Cold-waer sreams in norhern Pennsylvania, where
Marcellus shale developmen is concenraed, have rela-
ively small low raes,60ye wihdrawals or racking have
been primarily rom surace waers, wih wihdrawals
rom public waer sysems indusrys second choice.61
Regulaors anicipae increased use o groundwaer in he
region over he coming years i he pace o drilling and
racking coninues.62
A 2014 repor by Ceres looked a indusry-repored daa
on 39,294 oil and gas wells racked beween January 2011
and May 2013, and deermined ha 39 percen were in
regions wih high waer sress and 8 percen were in
regions wih exremely high waer sress.63Waer sress
is a measure o waer compeiion in a region, and regions
wih high waer sress are hose where oal waer wih-
drawals (no jus or racking) make up 40 o 80 percen o
he oal waer available or wihdrawal, while exremelyhigh waer sress means ha more han 80 percen o
available waer is being wihdrawn.64The repor also
deermined ha over 36 percen o he oil and gas wells
included in he sudy were in regions ha will experience
groundwaer depleion.65
To rack he Barnet Shale in Texas, oil and gas companies
used groundwaer and surace waer in equal measure
unil 2006, and increased he use o surace waer o abou
70 o 80 percen o oal waer use rom 2007 o 2010,
bu have since increased groundwaer wihdrawals.66
Thegroundwaer wihdrawals are primarily rom he Triniy
aquier, which is among he mos depleed aquiers in he
sae.67
A paricular concern is he exen o which oil and gas
companies are compeing wih armers or access o
limied reshwaer resources. In 2012, a a Colorado
aucion o waer righs, oil and gas companies were he
op bidders, driving up waer prices or he saes armers
many o which were enduring severe drough condiions.68
In New Mexico, some armers affeced by severe drough
condiions are, in lieu o arming, selling heir righs o
irrigaion waer o oil and gas companies.69
This compeiion wih, or ourigh displacemen o, agri-
culural waer use will only increase i unconvenional oil
and gas developmen coninues o expand in counies ha
already ace waer sress, and ha are likely o experience
even larger waer supply problems as a consequence o
climae change.
Impacts on surface waters, forests and soils
The consrucion o new well sies and supporing inra-srucure are jus he irs sage in he indusrys harm o
surace waers, oress and soils. Each Marcellus Shale gas
well pad sis on abou hree acres o cleared land, and or
each sie anoher six acres is cleared o build supporing
access roads, pipelines and oher ossil uel inrasruc-
ure.70The indusrys consrucion projecs increase he
amoun o sedimen ha lows ino rivers and sreams,
causing ecological harm ha is compounded by excessive
waer wihdrawals.71Water tanks lined up in preparation for fracking.
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The Urgent Case for a Ban on Fracking 7
Foress and agriculural lands provide waershed-scale
ilraion as rainwaer and snowmel low ino rivers and
recharge aquiers.72Widespread shale developmen in he
Marcellus region is expeced o cover hundreds o hou-
sands o acres wih suraces ha are impervious o rains,
signiicanly disruping his ilraion.73New indusry
sies, pipelines and roads also expose more ores o more
clearing, changing he balance o wildlie, harming ores
healh and hus urher affecing waersheds and ground-waer recharge.74Air polluans, including ozone, can also
harm oress and agriculural lands ha are downwind o
oil and gas operaions.75
Waer qualiy in rivers, sreams and shallow aquiers, and
soil qualiy on agriculural lands, are urher hreaened
by spills o racking chemicals and o oxic oil and gas
indusry wases, as well as by inenional spreading o he
wases, or example, o de-ice roads given he sals in he
wases.76A recen sudy near acive drilling and racking
operaions in Colorado ound elevaed levels o knownand suspeced endocrine disrupors in surace waers and
shallow groundwaers, consisen wih wha would be
expeced rom spills o he chemicals used by he indusry
in racking luids.77
The oil and gas indusrys wases primarily he lefovers
o whas brough o he surace conain corrosive sals,
radioacive maerial, oxic meals, hydrocarbons, and
racking chemicals, as oulined in Box 2 (page 4). Each
year housands o leaks, blowous and spills rom he oil
and gas indusry involve hese wases, as well as various
racking chemicals ye o be injeced, and/or produced oil
and naural gas liquids. (See Box 3.)
In a shining example o he oil and gas indusrys capure
o regulaory policy, he indusrys hazardous wases rom
drilling and racking are exemped rom ederal regula-
ions on hazardous wase, simply by virue o having been
generaed by he oil and gas indusry.78I wases wih
similar characerisics were o be generaed by anoher
indusry, hey would be deemed hazardous.79
The liquid wases ha do no ge spilled are ypically
sen o indusrial reamen aciliies, processed or reuse
or injeced back underground ino disposal wells.87In
Pennsylvania, abou hal o he lowback wase is sen o
indusrial reamen aciliies, abou one hird is reused
and increasing amouns are injeced back underground
ino disposal wells, commonly afer being sen o Ohio or
Wes Virginia.88In Texas, Oklahoma and Norh Dakoa,
he dominan pracice is o dispose o liquid wases by
injecing hem back underground.89In Caliornia, regula-
ors have recenly haled he wase injecions a numerous
wells ou o concern ha he wases are being injeced
direcly ino aquiers.90
Treamen a indusrial wase aciliies is imperec,
allowing conaminans o low hrough ino rivers and
sreams. In 2013, scieniss repored ess on sedimen
rom he bed o Blacklick Creek, in Pennsylvania, a
he poin where effluen lowed ino he creek rom an
indusrial reamen plan wih a hisory o acceping oil
and gas indusry wases.91The sedimen conained grealy
enhanced levels o radioacive maerial, wih radiaion
a 200 imes he level ound in background sedimens.92
No only does his pu a risk hose who ea ish ha rely
on he ood chain rom his sream, bu i illusraes ha
reamen is no necessarily effecive. Baseline levels o
polluion, wih some larger polluion evens, are inheren
o drilling and racking or oil and gas.
Box 3 Accidents and spillsare business as usual
In 2008, ProPublicaexamined local and state govern-
than 1,000 cases of leaks and spills at oil and gas
industry sites.80According to the Denver Post, the oil
and gas industry has reported about 2,500 spills in
percent having contaminated surface water and 17
percent having contaminated groundwater.81In North
Dakota in 2011, the oil and gas industry also reported
over 1,000 spills.82An analysis by Energy & Environ-
mentlooked at available data and counted over 6,000
spills and other mishaps in 2012 alone from oil and
gas industry operations throughout the United States,
83A
subsequent analysis found at least 7,662 spills, blow-
outs, leaks and other mishaps in 2013 in 15 top states
for onshore oil and gas activity.84In Pennsylvania, theDepartment of Environmental Protection has recorded
209 incidents in which the oil and gas industry either
85
All of these estimates are conservative, given that they
-
cult to identify. A PhD thesis in Petroleum Engineering,
completed in May 2014 at Louisiana State University,
explains that underground blowouts may just appear
to occur less frequently than those that reach the
86
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To he exen ha reamen is effecive, i concenraes
he conaminans and hus generaes solid wase. Toxic
hydrocarbons, heavy meals and radioacive maerial also
become concenraed in sludge a he botoms o wase
pis and in sludge and scale deposis wihin equipmen,
such as wihin pipes and anks.93Radiaion rom hese
concenraed wases, or rom he rock cutings brough o
he surace during drilling, is seting off deecors a he
gaes o landills.94Massive quaniies o low-level radioac-
ive wases pass hrough hese deecors, wheher opera-
ional or no, and ge dumped in landills,95i hey are no
irs spilled beside a road on he way o a landill.96The
indusrys radioacive solid wases are also being illegally
dumped.97
Under a previous governor, Norh Carolinas Deparmen
o Environmen and Naural Resources warned ha layerso cutings could resul in plugging o he landill and o
evenual spills o luid, known as landill leachae, ha is
enriched wih diverse conaminans, including he radio-
acive maerial.98Given ha he hal-lie o radium-226 is
1,600 years, such spills would ain he surrounding soil
and waershed or cenuries.99
Surace-waer conaminaion also resuls when conven-
ional wasewaer reamen aciliies ha are no
equipped o rea racking wasewaer noneheless receive
i. The conaminans can pass righ hrough hese acili-ies and be discharged ino rivers, causing problems or
waer sysems downsream, as well as or aquaic lie.100
When downsream waer uiliies disinec river waer
wih elevaed levels o chloride or bromide wo sals
ha characerize racking wasewaers101 he resuling
chemical reacions can orm harmul byproducs ha are
linked o cancer and birh deecs and ye are difficul o
remove once presen in drinking waer supplies.102
Raher han simply no allow surace disposal, he EPA
is drafing rules ha would require pre-reamen o
shale gas wasewaers beore hese wases could be sen
o convenional reamen aciliies ha serve public
waer sysems.103And since racking is also occurring in
non-shale ormaions, guidelines or only shale orma-
ions are inadequae. However, as is he case wih rounds
o wasewaer recycling and indusrial reamen, his
sole pre-reamen concenraes he oxins, creaing newdisposal problems.
Aquifer contaminationIn addiion o conaminaing armland and waersheds,104
plumes rom leaks and spills o liquids a he surace can
seep down ino soil and can conaminae shallow aquiers,
as a signiican racion o spills have done in Colorado.105
Bu aquiers also ace unseen hreas rom below, boh
immediae and over he long erm.
Disproporionaely high levels o arsenic, as well assronium, selenium and barium, have been ideniied in
groundwaer in areas o he Barnet Shale region in Texas
ha have seen more oil and gas aciviy.106The presence
o hese conaminans was believed o be due o heir
increased mobiliy, as a consequence o eiher nearby
waer wihdrawals or mechanical disurbances, such as
vibraions inroduced during drilling and racking.107
In a handul o incidens, oil and gas companies have
injeced racking luids or oil and gas indusry wases
very close o, i no direcly ino, underground sources
o drinking waer.108Beyond hese cases o direc
conaminaion, a nework o differen pahways can allow
conaminans o indirecly seep ino and conaminae
groundwaer rom below, in he afermah o drilling and
racking.109The pahways include new racures creaed by
hydraulic racuring, exising naural racures and auls,
and openings along wells wih compromised consrucion,
or inegriy.110
Methane and other hydrocarbon gases
A sudy published in 2000 esimaed ha ens o hou-
sands o oil and gas wells in Norh America were leakinggas, including ino he amosphere and ino shallow
aquiers.111
In 2011, scieniss observed ha mehane concenraions
in samples rom waer wells locaed in regions o acive
Marcellus and Uica shale gas developmen were 17 imes
higher, on average, compared o samples rom waer
wells in regions wihou drilling and racking aciviy.112
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The Urgent Case for a Ban on Fracking 9
The auhors concluded ha leaky well casings were he
mos likely cause.113In 2013, several o he same scien-
iss sudied 141 wells in Pennsylvania and ound higher
mehane concenraions by a acor o six on average
in waer wells locaed less han abou 3,200 ee (i.e.,
1 kilomeer) rom a naural gas well, compared o waer
wells locaed arher away rom any naural gas well.114
While mehane isel may no be oxic, is presence inaquiers indicaes he presence o oher hydrocarbons ha
are oxic. (See Box 2, page 4.) When a mix o hydrocarbon
gas eners unvenilaed spaces hrough conaminaed
waer wells, i can cause suffocaion and even resul in
explosions.115Mehane ha conaminaes aquiers may
also, hrough geochemical reacions or oher mechanisms,
increase levels o arsenic and oher harmul oxins in
waer brough o he surace.116
Ulimaely, he mehane and oher hydrocarbons may or
may no originae rom he rock ormaion being argeed,
bu he resul is he same: he mehane and oher hydro-carbons are presen a increased levels as a consequence
o drilling and racking. There are many well-sudied
reasons why, and he scale o he problem derives rom
he scale o widespread drilling.
Abou 2.6 million onshore oil and gas wells have been
drilled in he Unied Saes since 1949,117and abou 1.1
million o hese are acively producing.118More han 20
years ago, he EPA esimaed ha abou 200,000 o he
over 1 million abandoned oil and gas wells in he counry
were inadequaely plugged, meaning ha hey providepahways or hydrocarbon gases, i no oher luids,
o low up o he surace or o underground sources o
drinking waer.119
Addiionally, over 30,000 wells have been drilled or he
purpose o disposing o oil and gas indusry wases, via
injecion.120A gray area lies in how he indusry akes
brines brough o he surace and hen pumps hem back
underground ino wells o improve he low o oil ou o
adjacen wells; here are more han 110,000 o hese injec-
ion wells or enhanced oil recovery.121
Consruced o concree and seel, all o he above wells
age and degrade over ime.122Moreover, rom he begin-
ning o heir consrucion, a signiican racion o oil
and gas wells several percen have well inegriy
problems, meaning ha injeced luids, hydrocarbons
and ancien brines may no be conained wihin he
inner ubing, or casing, o he well.123 Once ouside o his
casing, hese conaminans give rise o polluion when
hey escape o he surace or move ino underground
sources o drinking waer ha were drilled hrough in
order o consruc a well.124
Due o a variey o reasons, including cemen shrinkage
and/or poor bonding, space can orm beween he ouer
shell o cemen and he various rock ormaions hrough
which an oil and gas well passes, creaing a pahway or
he poenial low o conaminans.
125
A PhD hesis in peroleum engineering, compleed in
May 2014, explains ha highly pressurized luids during
hydraulic racuring can direcly cause such separaion,
resuling in underground blowous evens in which
racking luids ravel back along he pah o he well
beween he concree and he rock ormaion, raher han
ino he argeed ormaion.126Compared o blowous ha
spew luids ino he air a well sies, hese blowous are
more difficul o deec, or obvious reasons.127
Fluids may also leak rom oil and gas wells hrough smallracures or channels ha orm wihin he inerior o
he consruced well, eiher wihin he cemen isel or
beween concenric cylinders o cemen and meal pipe,
or casing, used o build he well.128Improper cenering o
casings gives rise o less uniorm lows o cemen during
he consrucion o he well, and his in urn is anoher
acor ha increases he risk o well inegriy ailures.129
Gradual setling over ime due o he exracion o oil and
gas also applies sress ha may evenually break, or crack,
consruced wells, leading o ailure.130
A well head after fracking equipment has beenremoved from the drilling site.
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As he many differen mechanisms o well ailure sugges,
he problem o leaky wells, and ourigh well ailure, is
he opic o a large number o sudies by indusry and
academic scieniss. The botom line, however, is ha
many oil and gas wells leak, and ha he causes o leaks
are difficul o deec and ix, given ha hey occur or
so many differen reasons, subjec o diverse geological
condiions and o diverse indusry pracices.
A major concern is ha, as a given years newly drilled and
racked wells decline in producion and degrade physically,
he percenage ha develop inegriy problems is likely
o increase over ime.131Ye daa on he incidence o well
inegriy problems as wells age are severely limied, no
leas because shale gas and igh oil wells are relaively
new. A 2003 sudy looked a ederal daa on he over
10,000 wells drilled ino he ouer coninenal shel o he
Gul o Mexico a he ime, and ound ha more han 40
percen o hose ha were over 10 years old displayed
susained casing pressure, meaning ha he wells wereno conaining hydrocarbon gas wihin he inner ubing, or
casing, used o channel hydrocarbons up or producion.132
Now, according o a 2014 sudy, iniial daa on shale gas
well inegriy in Pennsylvania do no bode well or he
uure.133In he Marcellus Shale region o Pennsylvania,
shale gas wells have proven o be more prone o well
consrucion impairmens linked o well inegriy
problems, compared o convenional wells, especially in
he norheasern par o he sae, where over 9 percen
o shale gas wells have indicaions o compromised well
inegriy.134
Conaminaion o aquiers rom mehane and oher hydro-carbon gases alone warrans precauion over widespread
drilling and racking. However, anoher major concern is
ha evidence o sray gas conaminaion could be indica-
ive o uure waer qualiy degradaion, similar o ha
observed in some convenional oil and gas ields.135One
reason is ha such conaminaion could be a harbinger o
conaminaion rom he migraion o oher luids, no jus
he relaively buoyan hydrocarbon gases.136
Hydrocarbon gases in aquifers
as a sign of more problems to come
I oil and gas companies drill and rack he hundreds
o housands o new shale gas and igh oil wells envi-
sioned, he legacy o aging, degrading and increasingly
compromised wells will grow subsanially. This legacy
may lead o long-erm, region-wide changes in how luids
mix and move underground over he coming years and
decades. How hese changes migh impac he qualiy o
underground sources o drinking waer remains unknown,
highlighing he enormous risks inheren o widespread
drilling and racking.
Aquiers are immediaely pu a risk when he leadingedge o injeced racking luid propagaes new racures
arher han anicipaed, reaching nearby oil and gas
wells, or injecion wells ha have compromised cemening
and casing.137These rack his, or so-called well-o-well
communicaion evens, someimes give rise o surace
spills,138and hey are occurring or a leas wo reasons.
Firs, predicing he acual lengh o racures is a noori-
ously difficul mahemaical problem, sensiive o param-
eers ha are speciic o he geology surrounding each
individual well, and his sensiiviy leads o some racures
propagaing arher han expeced.139Second, he locaionsand dephs o many housands o he more han 1 million
abandoned oil and gas wells in he Unied Saes are no
known.140
The issue o rack his is oreshadowed in regulaions se
orh by he EPA under he Sae Drinking Waer Ac, and
exposes a complicaed sory abou he oil and gas indus-
rys capure o U.S. regulaory policy. (See Box 4, page 11.
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The Urgent Case for a Ban on Fracking 11
Box 4 Oil and gas industry injectionsUnder authority from the Safe Drinking Water Act, the U.S. EPAs
141In 1989, the U.S. Government
water via nearby abandoned wells that had integrity problems.142These
were frack hits, without the fractures.
-
burton Loophole, since it was created through legislation crafted behind
143
144
that would require addressing the issue of frack hits, were it not for
this loophole.145The loophole thus explains how the issue of frack hitshas remained beyond regulation, and highlights how the oil and gas
industry, through its capture of U.S. energy policy, has erected barriers to
protecting public health and the environment.
are triggered.146
being to just use a circle with a quarter-mile radius.147Alternatively, applicants for permits can use a calculation based on
148In particular,
149
In 2004, a panel of experts convened by the EPA noted that these options were adopted even though much existing
drinking water] and actual injection rate).150
on operational assumptions made in the early 1980s,151and concluded that enough evidence exists to challenge the
water]... .152
The EPA, despite these strong statements, has kept the simplistic protections in place, having deferred action because
data show that the quarter-mile approach is inadequate.153
Most of these state agencies, as regulators of oil and gas development in their respective states, are party to the Inter-
154so as to prevent physical waste of oil or gas or loss in the ultimate
recovery thereof.155
which has created a platform for the oil and gas industry that gives the illusion of transparency.156
This episode illustrates how longstanding alignments between the oil and gas industry and state governments shape
-
(continued on page 12)
Fluid awaits injection at a fracking site.
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In addiion o he immediae risks o conaminaion rom
rack his, he incidens clearly illusrae how widespread
drilling and racking can change he conneciviy o a
nework o conaminaion pahways on a regional scale.
Several recen sudies have begun o approach he larger
concerns abou long-erm impacs on a regional scale,
highlighing he severely limied scieniic undersanding
o he issue, and underscoring he simple-mindedness o
he curren regulaory approach o oil and gas indusryinjecions. (See Box 4.)
A 2012 sudy used a simpliied mahemaical model o
explore how preerenial pahways or luid low, such as
auls and naural racures, can inluence he ime scale
in which injeced conaminans migh reach underground
sources o drinking waer under a wors-case scenario.163
The model suggesed ha slow conaminaion could
occur wihin a decade.164A second 2012 sudy ound
evidence o a mach beween he geochemical proile o
saliniy in shallow groundwaer in norheas Pennsylvaniaand ha o Marcellus brine, suggesing a preexising
nework o pahways (i.e., unrelaed o racking) beween
he Marcellus Shale and shallow groundwaer.165In
2014, anoher sudy demonsraed a way o reduce he
complexiy o modeling he slow low o conaminans
hrough naural auls,166wih an aim oward modeling
ha approaches a regional scale.167This effor o incor-
porae numerous wells and auls a a regional scale is
preliminary, based on simpliying assumpions abou he
geomery and parameers ha conrol low hrough hese
conaminaion pahways.168
The EPA, as par o is muli-year sudy o he poen-
ial impacs o hydraulic racuring on drinking waer
resources, has conraced researchers o model a handul
o simplisic conaminaion scenarios.169However, he
preliminary models are ar rom being employed o predic
and poenially reduce he likelihood o uure conamina-
ion evens semming rom a single racked well, much
less o address he prospec o conaminaion on a
regional scale ha communiies wih widespread drilling
and racking may ace.170
A he same ime, he oil and gas indusrys capure o
U.S. energy policy is also on display in he resuls o he
conraced research. The scieniss modeling he conami-
naion scenarios or he EPA view using heir novel
compuaional mehods o invesigae he likelihood o
conaminaion as somewha o a side noe, and pu equal
i no greaer emphasis on he poenial uure use o heir
mehods o increase he producion o hydrocarbons rom
hydraulically racured wells.171
ground sources of drinking water from oil and gas
industry injections is based entirely on either an
AoR approach) or, alternatively, on an overly simplistic
calculation using a decades-old mathematical formula
that is divorced from modern geological understandingand modern computational science.
With wells now tunneling horizontally more than two
miles through rock formations and being hydrauli-
cally fractured in tens of stages, and with hundreds
without diesel injected at each stage, much has
changed since the operational assumptions made
in the 1980s that led to the AoR criteria. Yet fracking
injections that do not contain diesel fuels are not even
Loophole, and until recently fracking injections that
do involve diesel fuels have been in regulatory limbo.
predictably problematic. The Environmental Integrity
Project revealed that many companies had edited
their previous submissions to FracFocus.org, thereby
rewriting history and concealing their use of diesel
157
158
While the guidance acknowledges that the simplistic
assumptions for the formula approach do not apply, it
merely recommends that regulators use one of several
159
The guidance is most remarkable in that it still does not
draw on decades of progress in the mathematical and
computational sciences, emphasizing only that such
160
Moreover, the guidance does not mention the modeling
ongoing study of contamination pathways related to
hydraulic fracturing.
In June 2014, in unspoken disapproval of the EPAsguidance on diesel fuels, a GAO report pointed to
new risks to underground sources of drinking water
presented by hydraulic fracturing with diesel fuels
experts to review the risks.161The report also notes that
the surge in the volume and frequency of the oil and
rock formations, leading to surface spills162 events
that are akin to the surface spills from frack hits.
(Oil and gas industry injections
continued from page 11)
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The Urgent Case for a Ban on Fracking 13
The EPAs recen guidance on he use o diesel uels in
racking luids merely noes ha modeling o acually
calculae he poenial exen o he migraion o injeced
luids ofen requires a signiican body o daa.172This
saemen is a reerence o he ac ha acually deer-
mining when and where conaminaion evens are likely
o occur requires deailed inormaion ha is speciic o
he geology surrounding individual wells across a region,
including he presence o nearby naural auls and rac-ures, induced racures rom racking, and compromised
wells. Ye his inormaion is no always available.
Acually deermining when and where conaminaion
evens are likely o occur would also require knowledge o
he parameers ha conrol low hrough hese poenially
conneced pahways, over long periods o ime. These
parameers are highly uncerain, and vary by locaion.
Ye he oupus o he models are likely sensiive o he
parameers used, and o he assumpions ha hese
parameers embody. For example, assuming ha here isno naural aul providing a poenial pahway or conam-
inaion, when in ac here is one, undamenally changes
he model. The resul is ha crucial inormaion o ensure
proecion is no available.
As one ederal scienis old journaliss a ProPublica,
[]here is no cerainy a all in any o his You have
changed he sysem wih pressure and emperaure and
racuring, so you don know how i will behave.173 The
uncerainy over how he hydrogeological sysem will
respond raises he specer o long-erm aquier conami-
naion as a icking ime bomb, wih grave implicaions
or waer availabiliy, and or local economies, across he
counry. This risk is simply unaccepable.
Earthquakes, Lightning Strikesand Exploding TrainsScieniss now believe ha, by pumping large amouns
o luids underground, he oil and gas indusry is largely
o blame or he signiicanly increased requency o
earhquakes observed in he Unied Saes in recen
years.174
For decades, he cenral and easern Unied Saesconsisenly regisered abou 20 magniude 3.0 or greaer
earhquakes per year.175 In he mid-2000s, his rend broke,
and earhquake requency increased, direcly coinciding
wih he expansion o modern drilling and racking.176
In 2010, 2011 and 2012 combined, here were abou 300
earhquakes o magniude 3.0 or greaer.177In jus he irs
hal o 2014, Oklahoma alone regisered abou 200 magni-
ude 3.0 or greaer earhquakes.178
In a handul o cases, he evidence suggess ha he
speciic process o hydraulic racuring has also induced
earhquakes, mos recenly in Ohio.179Mos o he oil and
gas indusry earhquakes, however, are evidenly occur-
ring when high-volume wases ha are injeced ino UIC
Class II wells lubricae auls, or increase pressure beyond
he srengh o inersecing auls.180A 2014 sudy has
repored evidence ha injecion o oil and gas indusry
wases is riggering earhquakes cenered up o over 20miles away rom he injecion well, in par because o
modern, very high-rae injecion wells.181
A magniude 4.7 earhquake was among he swarm o
1,000 smaller earhquakes all measured in Greenbrier,
Arkansas, in 2010 and 2011, again atribued o injecions
o wases.182Among he oil and gas indusry earhquakes
ha have shaken Oklahoma, none was larger han he
magniude 5.7 earhquake in 2011 ha sruck Prague,
Oklahoma, resuling in injuries o wo people and
he desrucion o 14 homes.183
Now, a 2013 sudy hassuggesed ha large remoe earhquakes ar rom he
Unied Saes may acually be riggering earhquakes
wihin he Unied Saes, including he magniude 5.7
earhquake ha hi Prague, Oklahoma.184Tha is, oil and
gas indusry injecions appear o be bringing auls o
near-criical hresholds, and hen seismic waves rom large
bu remoe earhquakes can hen rigger he movemen o
hese auls.185
Residential damage from the magnitude 5.7 earthquake in
2011 that struck Prague, Oklahoma.
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Ideniying when and where criical hresholds are
nearly reached requires monioring ha can only be
done remoely, and hus imprecisely, given ha auls are
buried deep underground. This phenomenon o criical
hresholds being remoely riggered emphasizes he large
uncerainies ha cloud he quesion o when and where
he nex oil and gas indusry earhquake will srike. Jus
how srong and poenially desrucive and cosly he
indusrys earhquakes migh become also remains anopen quesion.
In some cases, he luids injeced by he oil and gas
indusry have evidenly enered and acivaed previously
unknown auls.186The ac ha here are unknown auls
urher highlighs undamenal limiaions o under-
sanding, and predicing, when and where he nex oil
and gas indusry earhquake will occur. This ac likewise
highlighs ha assumpions abou he nework o waer
conaminaion pahways wihin a neighborhood o a given
injecion well can change.More generally, he seismic waves ha make up earh-
quakes wheher unleashed naurally or induced by he
oil and gas indusrys injecions may exacerbae he
problem o leaky oil and gas indusry wells. The seismic
waves pass hrough a differen dephs a differen speeds,
owing o differences in he densiy (and elasiciy) o
he underlying layers o rock ormaions peneraed by
an oil and gas well. As a consequence, seismic waves do
no uniormly shake he consruced wells, resuling in
physical sresses ha can only increase he likelihood o
cemening or casing ailures.
Oil and gas indusry earhquakes have aken many by
surprise, bu scieniss have long known ha injecions
(and wihdrawals) o luids beneah he surace can induce
earhquakes.187Few, i anyone, however, anicipaed he
recen incidens in Norh Dakoa in which anks holding
oil and gas indusry wases have been sruck by lighning,
resuling in explosions ha spilled conaminans ono
surrounding lands and burned or days.188The sorage
anks are evidenly exploding because, in an effor o
avoid corrosion, he meal anks are lined wih iberglass,
which has much lower conduciviy han meal and hus
overheas.189
Trains carrying igh oil rom drilling and racking in he
Bakken region o Norh Dakoa are also exploding.190
The surge in igh oil producion in Norh Dakoa and
Texas has led o a rapid expansion in he ranspor o
oil by rain o reineries, in par because producion has
oupaced pipeline consrucion.191Energy Secreary Ernes
Moniz has noed ha he oil indusry has acually begun
o preer ransporing oil by rain, or he lexibiliy i
offers.192However, several oil rain explosions mos caa-
srophically in Lac-Mganic, Qebec, which desroyed
several blocks o he own and killed 47 people havebrough he so-called bomb rains o he oreron o
public atenion.193
The our high-proile explosions hus ar in Qebec,
Virginia, Alabama and Norh Dakoa relec ha he oil
conains relaively large amouns o naural gas liquids,
which are highly explosive.194The explosions also relec
ha large quaniies ofen more han 2.5 million gallons
per rain are now being sen very long disances by rail
o reineries, ypically abou 1,000 miles.195
The oil rain explosions have brough he issue o rackingo regions ha are no acively argeed or racking,
including Minnesoa, Washingon, D.C., Alabama and
he Paciic Norhwes.196For example, abou 250 oil
rain cars pass hough downown Seatle each day, and
recenly several o hese cars derailed a low speed,
wihou inciden, serving as a poenial wake-up call or
he ciy.197An analysis o planned projecs or expanding
reinery capaciy in he region ironically including he
conversion o aciliies inended or renewable liquid uels
would add as many as 12 one-mile-long oil rains each
day o he Norhwes railway sysem.198
Taken ogeher, he earhquakes, lighning srikes and
exploding rains are a reminder ha widespread drilling
and racking now means many differen hings o he
communiies ha are affeced in differen ways. Bu
nohing affecs residens o hese communiies living
alongside oil and gas indusry sies more viscerally han
he oil and gas indusrys air polluion, which lows along
wih he indusrys climae polluion.Aftermath of the Lac-Mgantic, Quebec, oil trainderailment in July 2013.
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The Urgent Case for a Ban on Fracking 15
Air and Climate ImpactsIn essence, drilling and racking gives rise o hree
differen sreams o polluans lowing ino he air: he
clouds o silica dus rom mining or and managing he
sand used in racking luids; he plumes o combusionbyproducs rom engines, lares and explosions; and he
sream o polluans ha he oil and gas indusry boh
brings o he surace and leaks ino he air.
Compromises wih he indusry call or more monioring
o beter undersand precisely wha he risks o oxic
exposures are or everyone living alongside drilling and
racking operaions, bu calls or prolonged monioring
and more sudies jus guaranee urher polluion, and
urher harm. Even assuming ha srong regulaion and
oversigh can be pu in place, and ha negligence, acci-
dens and explosions can be eliminaed, he baseline levelo he indusrys air and climae polluion will guaranee
cerain harm o public healh and will lock in unaccep-
able climae risks. The indusrys air and climae polluion
is bes avoided alogeher wih a ban on racking.
Silica dustClouds o silica dus orm a well sies as sand is managed
and prepared or mixing ino racking luid.199Silica dus
clouds also emanae rom silica mining and processing
sies. As wih he issue o exploding oil rains, silica sand
mining has broadened he reach o rackings impacsbeyond regions argeed or shale gas and igh oil exrac-
ion, wih large amouns o silica mined rom or processed
in Wisconsin, Minnesoa, Illinois and Iowa.200
A recen review o he public healh impacs o drilling
and racking summarizes ha [r]espirable silica can
cause silicosis and lung cancer and has been associaed
wih uberculosis, chronic obsrucive pulmonary disease,
kidney disease, and auoimmune disease.201The Naional
Insiue o Occupaional Saey and Healh measured
silica levels a 11 well sies, as silica sand was being
managed, and ound ha exposures exceeded hresholds
se o proec worker healh, in some cases by a acor o
10.202
Residens living nearby operaions may also ace serious
healh risks. The breahing par o i isn good. You canjus eel i in your hroa, eel i in your nose, explained
an individual living across he sree rom a Wisconsin
sand-washing plan.203Bu he speciic consequences or
hose living nearby sand mines and drilling sies remain
unknown, and largely unsudied.204A school in New
Auburn, Wisconsin, siuaed near our silica sand mines,
has ound silica on air ilers used in he schools air
sysem, suggesing ha low-level exposure in he commu-
niy may be he norm.205
Byproducts from combustionExhaus rom he diesel generaors and large rucksha crowd well sies, and smoke rom laring a well
sies, processing plans, and compressor saions, no o
menion explosions, creae a second sream o oxic air
emissions.
Along wih carbon dioxide rom combusion, hese plumes
conain variable amouns o hazardous air polluans,
including nirogen dioxides, carbon monoxide, pariculae
mater, and volaile organic compounds (VOCs), such as
he hydrocarbons benzene, oluene, ehylbenzene and
xylenes (BTEX) and various polycyclic aromaic hydrocar-
bons (PAHs).206
Hundreds o heavy-duy ruck rips per well are required,
largely o ranspor waer, chemicals, and equipmen, as
well as he wases ha resul rom drilling and racking. 207
Geting he indusry o conver o lees o rucks and
generaors ha burn naural gas would lessen he air
qualiy problems rom diesel exhaus, and he respira-
ory and cardiovascular healh problems associaed wih
such exhaus,208bu no wihou he ill effec o locking in
demand or more drilling and racking.
Smoke rom lares a well sies and processing plans
adds o he baseline levels o engine exhaus in much
less-deined ways, dependen on he efficiency o combus-
ion and he makeup o he wase gases being burned. O
course individual explosions are unoreseen, bu hey have
become an expeced consequence o business as usual,
and hey can lead o oxic smoke billowing or days.209
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The pollutants that oil and gascompanies bring to the surfaceThe hird sream o oil and gas indusry polluion orms
ou o he plumes o well- or sie-speciic mixes o
hydrocarbons and oher air and/or climae polluans, as
discussed in Box 2 (page 4). These are he polluans ha
come rom below ground, and ha are mobilized ino he
air in he afermah o drilling and racking. Now, based
on a handul o sudies in 2013 and 2014, i has become
clear ha he oil and gas indusry emis more air and
climae polluans han officials esimae.
The air and climae polluans ha oil and gas companies
bring o he surace include: mehane and oher VOCs,
such as he BTEX hydrocarbons and oher aromaic
hydrocarbons, including PAHs; hydrogen sulide; radon
derived rom radium presen in argeed rock ormaions;
and any chemicals rom racking suspended in he air as
vapor or aerosol, such as gluaraldehyde, ehylene glycol
and mehanol.210
Varying amouns o hese polluans low rom a vas
array o sources a successive sages wihin he indusry,
including: during drilling, cemening and casing; imme-
diaely afer racking luid injecion; rom sored wases;
rom any accidens, spills and explosions; and rom ine-
icien lares and leaky valves, langes, seals, pneumaic
devices, pipes and oher equipmen used o manage,
process, compress and ranspor he payoff hydrocarbons
he crude oil, naural gas liquids and naural gas. 211
Again, mehane is a poen greenhouse gas and a primarydriver o global warming.212The BTEX air oxics irriae
skin and can cause respiraory and nervous sysem
problems wih shor-erm exposure, and can cause greaer
harm wih long-erm exposure, including cancer.213In he
presence o sunligh, BTEX and oher VOCs also combine
wih combusion byproducs o orm ozone, a respiraory
irrian ha can prove aal or hose wih ashma. 214
PAHs ha all on land and surace waers can accumulae
in he ood chain, poenially resuling in harmul levels
o exposure or humans who consume conaminaed
ish.215Hydrogen sulide is highly poisonous, and oil andgas indusry workers a well sies may be advised o wear
personal moniors equipped wih alarms.216
The chemicals in racking luid, as well as largely
unknown byproducs o chemical reacions during
racking, are mobilized along wih hydrocarbon gases
and oher polluans, and emited ino he air o varying
degrees.217This pus he issue o racking chemical disclo-
sure ino proper perspecive as a signiican bu nonehe-
less singular componen o he indusrys polluion. Full
chemical disclosure would no pu an end o he indusrys
waer and air polluion.
The issue o racking chemical secrecy noneheless
resonaes wih he public, in par because i is an example
o he deerence ha policymakers regularly gran o
oil and gas companies, and because i illusraes how
such deerence holds back scieniic invesigaions o heindusrys impacs on public healh and he environmen.
Indeed, some in he oil and gas indusry have worked wih
he American Legislaive Exchange Commission (ALEC),
and ALEC has in urn helped o see ha sae legislaures
only consider disclosure requiremens ha are accepable
o he indusry.218Even when disclosure is required in
he even o emergencies, as is he case in some saes, a
company can be slow o comply.219
While regulaions vary by sae, rade-secre proecions
graned in he Toxic Subsances Conrol Ac mean ha
racking companies ypically do no have o disclose allhe chemicals hey pump underground.220In ac, in many
cases, oil and gas companies old off-he-shel producs
ino he racking luids ha hey make on-sie, wihou
acually knowing he chemicals conained in hese prod-
ucs.221
I is known ha oil and gas companies have injeced a
wide variey o oxic chemicals o racure wells, and have
injeced many more chemicals or which oxiciies are
no well sudied.222For example, among he chemicals
ideniied, over 100 are known or suspeced endocrinedisrupors.223Numerous known or suspeced carcinogens
also have been used since 2005 as addiives in hydraulic
racuring luids.224Many o he known chemicals used are
volaile, meaning ha hey escape readily ino he air.225
Very litle is known abou healh risks posed by mixures
o all he chemicals brough o he surace, and he exen
o chemical reacions ha orm dangerous byproducs.226
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The Urgent Case for a Ban on Fracking 17
Beyond inadequae requiremens or disclosure o racking
chemicals, here are many oher undamenal challenges
o quaniying he oil and gas indusrys releases or each
o he above polluans.
The challenges begin wih he number and diversiy o
sources, and how he consellaion o sources changes
over ime as he oil and gas indusry operaes, arges newareas and adops new pracices.227Geological differences
rom well o well, and differen sages wihin he oil and
gas sysem rom producion o disribuion give rise
o differences in he chemical composiions o wha ges
released ino he air.228The low rae and chemical compo-
siion o he plumes rom a single source can also change
over ime, under normal operaions,229and can increase
quickly, and unexpecedly, as a consequence o equipmen
ailures.
These acors make he size and chemical composiions
o he plumes in he hird sream o emissions variable, or
well- and sie-speciic. Imporanly, undersanding o he
indusrys emissions is blocked by lack o access o sies
and o daa held by oil and gas companies, presuming
ha hey have daa. As noed already, hese companies
are empowered by rade-secre proecions and by key
exempions graned o he oil and gas indusry under he
landmark environmenal laws. A PhD hesis compleed in
2014 reveals anoher obsacle o ull inormaion: sources
no couned a all, such as abandoned oil and gas wells
leaking mehane and oher hydrocarbon gases.230
Agains hese challenges, he EPA esimaes emissions
using a botom-up approach, beginning wih an invenory
o all o he differen indusry aciviies underaken in a
given year.231The EPA hen uses largely daed esimaes o
average emissions o each aciviy o arrive a an esimae
o oal emissions rom he oil and naural gas sysems.232
This approach relies heavily on volunary sel-reporing
rom he indusry.233
In 2013, he EPA Inspecor General ound many oil and
gas indusry emission acors o be o low or unknown
qualiy due o insufficien daa, leading o a resul ha
likely underesimaes acual crieria polluan emissions
rom oil and gas producion sources.234For example, here
are no emission acors or air oxics and VOCs emanaing
rom wase pis, rom produced waer anks, rom seps in
he well compleion process including he speciic process
o racking, and rom pneumaic devices, or pressure
valves.235
Daa on he acual levels o various hydrocarbons in
he amosphere, aken rom aircraf lighs and/or rom
surace monioring locaions, make possible an alerna-
ive, op-down approach o esimaing indusry emissions.
Using amospheric chemisry, scieniss ake hese daa
and hen combine hem wih daa on wind paterns o
esimae, working backward, wha he dynamic sreams
o mehane and oher hydrocarbons were ha lowed
ogeher over an oil and gas play and gave rise o he
hydrocarbon levels ha were measured.236
Scieniss using his aircraf measuremen approach in
Uah, Colorado and Pennsylvania sugges ha much more
mehane and oher air polluans are lowing rom oil and
gas sies han botom-up esimaes based on daed emis-
sion acors and indusry sel-reporing.237
Flying over an oil and gas ield in Uah one day in
February 2012, Karion e al. measured very large levels o
mehane he equivalen o beween 6.2 percen and 11.7
percen o naural gas producion ha monh, assuming
ha he day was represenaive o daily emissions ha
monh.238In April 2014, Caulon e al. published a sudy
o mehane emissions during he drilling sage a well
sies in Pennsylvania and ound several super-emiters,
each releasing 100 o 1,000 imes he EPAs esimae
o emissions during he drilling phase, as uilized in isbotom-up, invenory esimaes.239In May 2014, Pron e
al. looked a mehane emissions in he Denver-Julesberg
basin in Colorado over a wo-day srech in 2012 using
monioring equipmen on owers and on aircraf lown
above he play, and concluded rom he measuremens
ha mehane emissions were close o 3 imes higher han
an hourly emission esimae based on EPAs Greenhouse
Gas Reporing Program daa or 2012.240
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Because o variabiliy rom sie o sie, mehane emis-
sions can be used only as a crude indicaor o emissions
o oher polluans brough o he surace by he oil andgas indusry. Noneheless, hese resuls are consisen
wih he EPA Inspecor Generals conclusion ha curren
invenory esimaes undersae he oil and gas indusry
emissions o air oxics and oher VOCs, no jus mehane.
Imporanly, Pron e al. esimaed ha benzene emis-
sions were abou seven imes larger han he Colorado
invenory esimaes would sugges.241The ac ha
benzene emissions were evidenly no jus approximaely
hree imes larger, consisen wih he inding on mehane
emissions, bu closer o seven imes larger, shows how
simple, generic (i.e., linear) ormulas or inerring non-mehane VOC levels rom mehane levels can mislead.
Simple inerence o non-mehane VOCs rom mehane
can hide poenially crucial and harmul differences
in he composiions o he raw hydrocarbon gases rom
well sies, as well as hide differences in he composiions
o he differen sreams o naural gases managed a
differen sages in he naural gas sysem. In oher words,
ar more harmul gases han have been esimaed may
be lowing rom some wells in some regions, no jus
rom he Denver-Julesberg basin. This highlighs ha
widespread drilling and racking is a large, unconrolled
experimen, and ha he consequences or human healh
remain largely unknown.242
Top-down sudies based on aircraf measuremens only
provide a look a emissions over a shor ime span, and
rom sources wihin relaively small areas o indusry
aciviy. A paper published in December 2013 by Miller
e al. has suggesed ha, naionally, in 2010, leakage o
naural gas rom he oil and gas indusry in he Unied
Saes amouned o he equivalen o over 3 percen o
end-use naural gas consumpion ha year; ha is, he
auhors suggesed ha acual emissions were more han
30 percen higher han he EPAs esimae a he ime.243
In a review published in February 2014, Brand e al.
surveyed he scieniic lieraure on oil and gas indusry
mehane emissions and likewise concluded ha he
botom-up, invenory approach used by he EPA signii-
canly underesimaes naional mehane emissions.244
Natural gas dependence causes
more global warming than thought
Because undersanding o naional mehane emissions
is lacking, he climae impacs o widespread drilling
and racking are a mater o curren debae.245Bu he
overwhelming ocus o his debae on he climae impacs
o using naural gas insead o coal o generae elecriciy
loses sigh o he oil and gas indusrys role as a major
source o climae polluion.
Abou wo hirds o U.S. climae polluion sems rom he
oil and gas indusry, wih a litle under 30 percen sem-
ming rom naural gas producion, processing, ranspor
and use.246However, he esimaes o mehane leakage
used o arrive a hese igures are based on he official
underesimaes discussed above.247 The above igures on
climae polluion semming rom he oil and gas indusry
also hinge on comparisons o he relaive conribuions o
he differen greenhouse gases o global warming.248Now,
according o he consensus science ha is presened in he
mos recen Inergovernmenal Panel on Climae Change(IPCC) assessmen, i is clear ha officials have also been
grealy underesimaing he poency o mehane as an
agen o climae change.249
The IPCC now saes ha, pound or pound, a pulse o
mehane rom he oil and gas indusry raps 36 imes
more hea han a pulse o carbon dioxide, over a 100-year
ime rame, and raps 87 imes more hea over a 20-year
ime rame.250Remarkably, since he irs IPCC assess-
men repor, each subsequen repor in 1996, 2001, 2007
and mos recenly 2013 has increased he esimae o
mehanes global warming poenial, relaive o carbondioxide.251The mos recen increase was he larges,252
raising he quesion o wheher more increases are in
sore as climae science progresses.
Nowihsanding he signiican climae polluion rom he
naural gas sysem, advocaes o naural gas have oued
he uel as a ool or addressing he challenge o global
warming.253Debae over he climae impacs o swiching
o naural gas rom oher ossil uels has become conro-
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The Urgent Case for a Ban on Fracking 19
versial, in par because i is based on a alse choice: burn
naural gas or burn oher ossil uels. Framing he climae
impac o racking in his way loses sigh o hree crucial
poins.
Firs, mos recenly, racking is being done primarily o
exrac oil. Since he end o Augus 2012, abou 75 percen
or more o drilling rigs have argeed primarily oil, no
naural gas, and abou wo hirds o all he drilling rigsoperaing in he Unied Saes are he sor capable o
drilling horizonally hrough shale and igh rock orma-
ions.254Fracking makes i possible o bring o he surace
and burn much more oil han previously imagined, and
here has never been any preense ha such oil consump-
ion is anyhing bu bad or he climae.255Second,
increased naural gas use in he elecriciy secor does no
jus displace oher ossil uels, i displaces cleaner solu-
ions, such as solar, wind and efficiency.256Third, much o
he coal displaced, insead o saying underground, is jus
being expored and burned in oher counries, offseting,a an inernaional level, he U.S. reducions in carbon
dioxide emissions ha come rom swiching o naural
gas.257The claim ha hese oher counries would jus
burn coal rom elsewhere anyway258relecs he excep-
ionally low sandards or U.S. leadership on he issue o
global warming.
These hree caveas se aside, Food & Waer Wach ook a
close look a he condiions and assumpions under which
using naural gas insead o oher ossil uels migh acu-
ally mean marginally less global warming. Burning naural
gas does produce abou hal as much carbon dioxide
as burning coal, wih less poenial or carbon dioxide
reducions when using naural gas insead o heaing
oil, gasoline or diesel.259However, hese poenial carbon
dioxide reducions are offse by he leakage o mehane
rom he naural gas sysem, and jus how much hey are
offse remains an open and conroversial quesion.260
There are a variey o ways o compare mehane emis-
sions o carbon dioxide emissions, in order o begin o
quaniy he climae impacs o burning naural gasinsead o coal, or heaing oils, or gasoline or diesel.261
Mehane does no persis in he amosphere or as long
as carbon dioxide, so merics used o compare emissions
o he wo greenhouse gases depend on he ime rame
considered.262Focusing on he nex ew decades, a ime
rame in which mehane raps much more hea han
carbon dioxide does, pound or pound,263is necessary or
hree undamenal and pressing reasons.264
The irs reason is ha we ace he risk ha climae
ipping poins will be surpassed in he near erm, meaning
ha naural posiive eedbacks could kick in and lead oirreversible changes.265For example, reduced Arcic ice
coverage means more absorbed sunligh and warming.266
Furher, any warming ha haws ice crysals ha had
rapped mehane will give rise o more mehane emis-
sions, and hus more warming.267Indeed, hawing o
permaros in he Yamal Peninsula in Russia, and he
subsequen release o massive amouns o mehane,
likely explains he ormaion o seemingly botomless
craers in July 2014.268Second, even discouning he risk
o climae ipping poins, he changes o he climae ha
are already expeced o accompany 2 degrees Celsius o
pos-indusrial warming promise o be dangerous and
cosly.269Third, curren climae science warns ha o
have a good chance ha is, signiicanly beter han a
50-50 chance o keeping warming rom going beyond 2
degrees Celsius requires a very rapid ransiion off o all
ossil uels, leaving mos underground.270
Reurning o he quesion o mehane leakage, a 2012
sudy ound ha naural gas leakage ha amouns o
more han abou 3.8 percen o naural gas consump-
ion means ha swiching rom burning coal o burningnaural gas o generae elecriciy would be worse or
he climae or abou 20 years, a wash a 20 years, and
marginally less damaging hereafer.271The auhors
urher deermined ha leakage a abou 7