Collaboration, Not Confrontation with EPA

Mark Green
Posted July 10, 2012

EPA’s big study of the impact of hydraulic fracturing on drinking water is due in 2014, but an interim report might surface as early as the end of the year. Needed is focused, scientifically solid research that that will advance public discussion of shale energy development that has so much potential for our economy and future energy security.

Unfortunately, EPA’s study plan has deficiencies that ultimately could sap the integrity of the study’s findings. That’s one of the conclusions in a new analysis by the Battelle Memorial Institute. Stephanie Meadows, API upstream senior policy advisor, shared some of the study findings in a conference call with reporters:

“Battelle’s analysis of the plan, which we are releasing today, reinforces many of our previously stated concerns and raises some new ones. It finds deficiencies in the rigor, funding, focus and stakeholder inclusiveness of EPA’s plan. … We’re not calling on EPA to stop its study. We’re calling on them to do it right.”

API and America’s Natural Gas Alliance (ANGA) commissioned the Battelle study after EPA declined to engage with industry in a collaborative review of hydraulic fracturing. Battelle’s Bernard Metzger said his broad-based multidisciplinary team of engineers, oil and natural gas experts, toxicologists and others examined EPA’s study plan to determine its soundness. The findings include:

• EPA is reaching beyond the relationship between hydraulic fracturing and drinking water resources, which was its charge from Congress, to broader oil and natural gas industry production activities.
• The expanded scope suggests there will be added complexity, risk, and uncertainty in EPA’s study, raising the level of difficulty in ensuring a scientifically rigorous result.
• Site data collected from companies comes from the years 2006-2010, making it likely some data in the final 2014 report could be nearly 10 years old. Changes at company sites in the intervening years likely will “render the data obsolete for the purposes of the study.”
• Case studies were selected from a limited and statistically biased pool and lack necessary baseline information which may result in incorrect and flawed conclusions. 
• The plan suffers from a lack of “significant” industry collaboration, given industry’s extensive experience and expertise in hydraulic fracturing and associated technologies.

Metzger said gaps in EPA’s study planning can impact data quality:

“Quality cannot be built into the back end of a project through rigorous review; it must be built into each step of a scientifically rigorous process to ensure that the end product is high quality data that is defensible and achieves the study goals.”

ANGA’s Amy Farrell:

“We continue to believe a well-designed, scientifically rigorous study of hydraulic fracturing will confirm our industry’s ongoing commitment to safe and responsible development and that communities don’t have to trade the protection of the environment for the many economic, energy security and clean air benefits natural gas offers. We hope (EPA) will not only consider additional efforts to collaborate with the industry and other key stakeholders moving forward, but that they will carefully review the (Battelle) report and consider the critiques and recommendations for improvement and make adjustments as appropriate.”