Teague Soderman
701 Jackpine Ct
Sunnyvale CA 94086
Department of Conservation
ATTN: Well Stimulation Regulations
801 K Street, MS 24-02
Sacramento, CA 95814
To Whom It May Concern,
I would like to thank the California Department of
Conservation for the opportunity to comment on revisions to SB 4 Well
Stimulation Treatment Regulations.
This is a moment at which anyone with the capacity for
reflection should stop and wonder what we are doing.
If the news that in the past 40 years the world has lost over
50% its vertebrate wildlife (mammals, birds, reptiles, amphibians and fish)
fails to tell us there is something wrong with the way we live, it’s hard to
imagine what could. Who believes that a social and economic system that has
this effect is a healthy one? Who, contemplating this loss, could call it
progress?
There seems to be some kink in the human brain that prevents
us from stopping, that drives us to carry on taking and destroying, even when
there is no need to do so.
Every year, new fracking chemicals, new mining methods, and new
techniques for extracting oil and gas are developed. We are waging an
increasingly asymmetric war against the living world.
This is what hits me harder than anything: the disproportion
between what we lose and what we gain. Economic growth in exchange for
environmental destruction and pollution of our ground water, is not done in the
interest of current and future generations of Californians.
According to an article in RT published October 9th,
2014 (ref: http://rt.com/usa/194620-california-aquifers-fracking-contamination/)
the Environmental Protection Agency found that industry had illegally injected
about 3 billion gallons of fracking wastewater into central California
drinking-water and farm-irrigation aquifers, which supply quality water in a
state currently suffering unprecedented drought. After the US ordered a review
of possible contamination of the aquifers—which are supposed to be protected by
state law and the federal Safe Water Drinking Act—the state found them riddled
with toxic fluids. The California State Water Resources Board found high levels
of arsenic, thallium, and nitrates in the toxic soup left
behind by the hydroaulic fracking injection sites used to unleash energy
reserves deep underground; arsenic is a carcinogen that weakens
the immune system, and thallium is a common component in rat poison. Clean
water is one of California’s most crucial resources, and documents like these
make it clear that state regulators have utterly failed to protect our water
from oil industry pollution.
Meanwhile, California is experiencing record drought and
water is an increasingly important and limited resource. Fracking uses a tremendous amount of water—2-8
million gallons of water may be used to frack a single well (some wells consume
much more) and a well may be fracked multiple times, each time increasing the
chances of chemical leakage into the soil and local water sources.
Where will the water used in the fracking process come from?
Changes to Section 1783.1 (21) remove requirements to identify protected water
reserves, to test water before and after fracking, and to disclose where the
water used in the process came from.
What if something goes wrong? Changes to Section 1787 “Well
Monitoring After Fracking “removes the requirement of well operators to take
appropriate measures to prevent contamination of protected water in the event
of a well breech, and reduces operator monitoring requirements for fluid
flowback. In other words, well operators can use our drinking water to extract
gas, and pollute our drinking water in the process, with limited accountability.
Research shows that fracking chemicals cause cancer and that
these chemicals can find their way into our water tables. The proposed changes to
Section 1785 “Monitoring During Fracking Ops“ redact requirements for
disclosing the chemical constituents of the fracking fluid in the event of well
breach. Well operators are not required to tell us what chemicals they are
pumping into the earth—even if those chemicals include radionuclides like
uranium or radium.
USGS data also shows that fracking can increase the
frequency and likelihood of earthquakes. California is earthquake territory,
yet the revisions to Section 1789 “Post-Fracking Report” removes earthquake
reporting requirements for earthquakes that occur in the vicinity of fracking
activity.
Will they be allowed to frack in your back yard? Section 1783.2
removes the requirement for giving notice before commencing fracking
activities, so that well operators do not have to alert property owners before
fracking within 500/1500 feet of your land. Isn’t that something most people
would like to know about?
Because of serious risks that fracking has a devastating
effect on human health and the environment, we urge you NOT to allow fracking
in California. Any guidelines being considered, should make the practice safer,
with more testing and oversight, rather than making it easier for industry to
frack in California. Below are the specific sections which are of concern:
·
Sec 1781. Definitions: removes “Protected Water”
·
1783.1 (12) Application for Permit to Frack: no
longer requires the true vertical depth and wellbore path for directionally
drilled wells
·
1783.1 (16): removes identification of any
existing wells that may be impacted by these fractures and modifications
·
1783.1 (17): removes requirement to disclose depth
of protected water, including method used to determine protected water
·
1783.1 (21): removes requirement for water identification
and analysis within the area of well stimulation treatment
·
1783.1 (DIII) Diverting Surface Water: removes
disclosure of how and where the water used during fracking will be acquired.
·
1783.2: removes requirement for notice before
commencing well stimulation treatment. They do not have to alert property
owners before fracking within 500 feet of your land.
·
1783.3 (A): removes requirement for follow-up
sampling 30-60 days after the well stimulation is completed.
·
1784 (5): lessens requirement to assess and
identify water sources near fracking area.
·
1785 Monitoring During Fracking Ops: redacts
requirement for disclosing chemical constituents of the fracking fluid in the
event of well breach.
·
1787 Well Monitoring After Fracking: removes
requirement to “immediately take all appropriate measures to prevent
contamination of all underground sources of protected water, hydrocarbon zones,
and all surface waters in the area of the well and shall provide the Division
and the Regional Water Board with the information described in section
1785(d).”
This section also reduces operator monitoring
requirements for fluid flowback.
·
1789 Post-Fracking Report: removes earthquake
reporting requirements in vicinity of fracking activity.
