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 9^th, 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.