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Seth B.C. Shonkoff, PhD, MPH
Executive Director | PSE Healthy Energy
436 14th Street, Suite 808
Oakland, CA 94612
December 16, 2014
The Honorable Martin O' Malley
100 State Circle
Annapolis, MD 21401-1925
Re: Maryland's Proposed Regulations on Shale Gas Development
Dear Governor O'Malley,
As a national organization comprised of physicians, scientists, and engineers, PSE Healthy Energy appreciates the opportunity to share with you our views regarding the recent decision to publish regulations that would allow shale gas development and production in Maryland. As you know, there has been much discussion concerning the potential impacts of shale gas development to the environment and human health. While there is still a dearth of quantitative epidemiology that assesses associations between risk factors and health outcomes, there is a growing body of science that has identified significant evidence of environmental hazards and public health risks [1–3]. Yet, until research catches up to the rapid growth of this industry, any regulations promulgated at this time will not be based on sound science.
In the recent announcement you made it clear that the regulations in Maryland will implement the best practices of other states and nations where hydraulic fracturing is permitted. Unfortunately, assurances of safety are no proxy for adequate protection. Every state that has allowed shale gas development thus far has made similar claims about its ability to regulate an industry that is largely exempt from federal oversight with little scientific understanding on how to manage risks. A recent study in northeastern Colorado found that even with tighter regulations on air pollutant emissions, shale gas development-sourced air pollution has actually increased . Every state with shale oil and gas development has had numerous reports of water contamination, air quality degradation, and self-reported poor health outcomes. Based on the available evidence, there is no reason to believe Maryland would be an exception.
What is especially troubling about this decision is that the results of a study by the Maryland Institute for Applied Environmental Health at the University of Maryland's School of Public Health seemed to have been largely ignored. This study pointed to a high or moderately high likelihood of public health impacts in eight different areas. Again, no state has been able to minimize the environmental and public health impacts of shale gas development to a level that many in the public health and medical communities would consider appropriate or acceptable. Gesturing to strong regulations and technological improvements that may mitigate some of these impacts is not only insufficient, but it ignores the available scientific evidence and bases policy on theoretical expectation rather than actual experience.
The peer-review process is the cornerstone of scientific inquiry. Our organization, PSE Healthy Energy, is committed to providing citizens and policymakers with objective, evidence-based information on energy production methods. Toward this end we have compiled a near exhaustive database of all the peer-reviewed articles on unconventional oil and gas development. This library is open to the public and can be accessed at http://www.psehealthyenergy.org/site/view/1180.
We have learned two very important points about shale gas development in the creation and review of this collection of scientific literature. First, there are clear, well-defined pathways of exposure (e.g., air, water) from shale gas operations to human populations. There are numerous investigations that have linked modern natural gas operations to surface and groundwater contamination and this is well documented in the peer-reviewed literature [5–9] and in Pennsylvania Department of Environmental Protection reporting which identified 248 cases of water contamination caused by natural gas development . Emissions of health damaging air pollutants such as nitrogen oxides (NOx), volatile organic compounds (VOCs), aromatic hydrocarbons, particulate matter (PM), and ground level ozone (smog) precursors including methane (CH4) and VOCs occur throughout the life cycle of shale gas development [11–14].
Second, while the science has grown tremendously in the past year, there are still significant data gaps that would provide guidance on the relative safety of shale gas development. Of the more than 400 peer-reviewed journal articles contained in the aforementioned database, 293 (~73%) have been published since the beginning of 2013 and 154 have already been published this year. What this suggests is that studies are underway and the scientific community is now playing catch-up with the rapid growth of this industry. We are only now beginning to understand the implications of this industry for the environment and human populations. Until better data emerge on the potential risks, we will not know whether or not shale gas development can be carried out safely.
Nonetheless, we can make some determinations on the environmental and public health impacts of shale gas development from this growing body of science. Our recent analysis of all the peer-reviewed studies directly pertaining to health outcomes, air quality, and water quality revealed the following: 87% of the original research on human health indicates potential risks or adverse health outcomes; 72% of the original research on water quality indicates potential, positive association, or actual incidence of water contamination; and 95% of the original research on air quality indicates elevated air pollutant emissions and/or atmospheric concentrations. This analysis is preliminary and is not without limitations; however, it does provide a general scientific consensus as of 2014. Unfortunately, this consensus gives no indication that shale gas can be developed safely. The analysis and accompanying bibliographic appendix is available at http://www.psehealthyenergy.org/site/view/1233.
Our organization, PSE Healthy Energy, is dedicated to supplying evidence-based, scientific information and resources on unconventional shale oil and gas development and other novel energy technologies to a variety of stakeholders. PSE Healthy Energy is an independent non- profit that provides evidence-based information on various forms of novel energy development. We maintain formal affiliations and relationships with faculty members across a range of disciplines at a number of national institutions, including Cornell University, University of Pennsylvania, Stanford University, George Washington University, and the University of California, Berkeley. Our mission is to bring scientific transparency to important public policy issues surrounding such methods by generating, organizing, translating, and disseminating scientific information. We invite you to contact us or visit our website at http://psehealthyenergy.org, where we provide high-quality resources and analyses on shale oil and gas development and other forms of energy production.
Once again, thank you for the opportunity to share with you our views regarding the decision to publish regulations that would allow shale gas development and production in Maryland. Please feel free to contact us with any questions.
Seth B.C. Shonkoff, PhD, MPH
Executive Director | PSE Healthy Energy
Visiting Scholar | University of California, Berkeley
Affiliate | Lawrence Berkeley National Laboratory
Adam Law, MD
Board Member | PSE Healthy Energy
Assistant Professor of Clinical Medicine | Weill Cornell Medical College
Jake Hays, MA
Director, Environmental Health Program | PSE Healthy Energy
Research Associate | Weill Cornell Medical College
1 Shonkoff SB, Hays J, Finkel ML. Environmental Public Health Dimensions of Shale and Tight Gas Development. Environmental Health Perspectives 2014;122. doi:10.1289/ehp.1307866
2 Adgate JL, Goldstein BD, McKenzie LM. Potential Public Health Hazards, Exposures and Health Effects from Unconventional Natural Gas Development. Environ Sci Technol 2014;48:8307–20. doi:10.1021/es404621d
3 Maryland Institute for Applied Environmental Health. Potential Public Health Impacts of Natural Gas Development and Production in the Marcellus Shale in Western Maryland. 2014.http://www.mde.state.md.us/programs/Land/mining/marcellus/Pages/Health_Study.asp x
4 Thompson CR, Hueber J, Helmig D. Influence of oil and gas emissions on ambient atmospheric non-methane hydrocarbons in residential areas of Northeastern Colorado. Elementa: Science of the Anthropocene 2014;2:000035. doi:10.12952/journal.elementa.000035
5 Fontenot BE, Hunt LR, Hildenbrand ZL, et al. An Evaluation of Water Quality in Private Drinking Water Wells Near Natural Gas Extraction Sites in the Barnett Shale Formation. Environ Sci Technol 2013;47:10032–40. doi:10.1021/es4011724
6 Gross SA, Avens HJ, Banducci AM, et al. Analysis of BTEX groundwater concentrations from surface spills associated with hydraulic fracturing operations. J Air Waste Manag Assoc 2013;63:424–32.
7 Jackson RB, Vengosh A, Darrah TH, et al. Increased stray gas abundance in a subset of drinking water wells near Marcellus shale gas extraction. PNAS 2013;110:11250–5. doi:10.1073/pnas.1221635110
8 Kassotis CD, Tillitt DE, Davis JW, et al. Estrogen and Androgen Receptor Activities of Hydraulic Fracturing Chemicals and Surface and Ground Water in a Drilling-Dense Region. Endocrinology 2013;155:897–907. doi:10.1210/en.2013-1697
9 Osborn SG, Vengosh A, Warner NR, et al. Methane contamination of drinking water accompanying gas-well drilling and hydraulic fracturing. PNAS 2011;108:8172–6. doi:10.1073/pnas.1100682108
10 Pennsylvania Department of Environmental Protection. Water Supply Determination Letters. 2014.http://files.dep.state.pa.us/OilGas/BOGM/BOGMPortalFiles/OilGasReports/Determina tion_Letters/Regional_Determination_Letters.pdf
11 McKenzie LM, Witter RZ, Newman LS, et al. Human health risk assessment of air emissions from development of unconventional natural gas resources. Sci Total Environ 2012;424:79–87. doi:10.1016/j.scitotenv.2012.02.018
12 Pétron G, Karion A, Sweeney C, et al. A new look at methane and non-methane hydrocarbon emissions from oil and natural gas operations in the Colorado Denver-Julesburg Basin. J Geophys Res Atmos 2014;:2013JD021272. doi:10.1002/2013JD021272
13 Pétron G, Frost G, Miller BR, et al. Hydrocarbon emissions characterization in the Colorado Front Range: A pilot study. J Geophys Res 2012;117:D04304. doi:10.1029/2011JD016360
14 Macey GP, Breech R, Chernaik M, et al. Air concentrations of volatile compounds near oil and gas production: a community-based exploratory study. Environmental Health 2014;13:82. doi:10.1186/1476-069X-13-82
- See more at: http://www.psehealthyenergy.org/site/view/1235#sthash.mXOzSaQ1.dpuf