Comments re Drilling in the Wayne National Forest

Drilling in the Wayne

I’d like to thank Christine Hughes for inviting me to participate this afternoon. I consider it an honor to be with you. Honestly though, I’ve struggled these past few days trying to figure out just what I’d like to say.

I suppose I could have said something about extractive industries and cycles of boom and bust in Appalachia. How coal production rose steadily in Ohio between 1950 and 1970 despite an 83% drop in the labor force. How the forests were cut and the streams polluted. I guess one person’s boom is another person’s bust. Why is it that people here have to sacrifice their land, and quite possibly their health, to make ends meet? Would it be any different this time around? I figured someone else might want to talk about that though.

I could have talked about how the U.S. is often touted as the Saudi Arabia of coal. And how huge deposits of natural gas in Appalachia are going to help wean us off foreign oil. At least that’s what the energy companies and politicians say. I’m still trying to figure that one out. No one seems to care that the U.S. is actually the Saudi Arabia of wasted energy. But this seemed too depressing. I didn’t want to go there.

I could have mentioned how absurd it is that all sorts of chemicals can get pumped into the ground to extract natural gas from deep deposits but we, as American citizens, are not allowed to know what those chemicals are, even though many of us suspect they’re harmful to human health and the environment. It’s a trade secret we’re told. It’s not hard to tell who is really running the country these days. Anyway, I’m terrible at keeping secrets so I had to scratch that one off my list too.

Here is what I do want to talk about today. Sixty years after publication of A Sand County Almanac by Aldo Leopold, we are still searching for a land ethic to guide our resource management decisions – one that views a wooded acre as something more than a set of building blocks for yet another suburban subdivision or the source of someone’s “cheap” energy.

I want to leave you with a few words from a piece Duke Law professor, Jedediah Purdy, wrote recently. He says . . .

“There is no equality among American landscapes: some are sacred, some protected against harm, and some sacrificed. As a result, there is no equality among Americans to the degree that they care about their landscapes, identify with them, and wish to imagine that their children and grandchildren might live there as they have. If you live in a wooded suburb of Boston and treasure the preserved lands next door, if you live in the dense neighborhoods of Boulder, Colorado, and like to duck into the Rocky Mountain National Park for your summer hikes, your relation to the land is secure, a privilege enshrined in law. But if you love the hills of southern West Virginia or Eastern Kentucky [or southeastern Ohio], if they form your idea of beauty and rest, your native or chosen image of home, then your love has prepared your heart for breaking.”

I scratch my head in disbelief sometimes. Is this really the 21st century?
––Geoff Buckley, Athens, May 23, 2012

Heather Cantino Comments, Athens Wayne National Forest headquarters, May 23, 2012:

The Wayne is responsible for evaluating significant impacts of any action it undertakes before irrevocably committing any resources. Leasing is an irrevocable commitment of resources. Therefore the EIS must happen now. The Wayne did not evaluate deep-shale drilling and horizontal fracturing in its 2006 Plan. This industrial technology has hugely significant impacts and must be evaluated by an EIS with full public input before the Wayne leases any more of the land it does control, because such leasing could entail fracking, especially in Washington County where Utica oil may be more profitable to extract.

We are so glad that you own mineral rights on at least some of your land, because at least this land can be protected. We are glad that you have full authority and responsibility to fully evaluate impacts to our community of any action on this land. You and we can protect at least this much.

I am confused though by references by Wayne officials to “evaluating surface impacts” when Forest Service Groundwater guidance documents clearly detail the Wayne’s authority over groundwater and community drinking water supplies. We are very glad that our local Wayne neighbors rather than the behemoth lease-crazy BLM is in charge of protecting our groundwater. We are glad that you have full authority, Anne, to say no to further leasing until you can be assured that there will not be harm to our drinking water from your actions.

We are concerned that groundwater has not been mapped in this area of the state. According to your agency’s guidance documents, such mapping must happen before you undertake any activities that may impact groundwater. Further leasing is clearly such an activity.

70,000 people depend on the shallow, highly permeable aquifer that lies along four Wayne parcels previously put up for bid. This aquifer is the sole source for Nelsonville, LeAx, Burr Oak Regional Water District, and Athens City. Abandoned mines underlie large areas of ALL these river parcels. Acid mine drainage corrodes both steel and concrete in a matter of decades. I am wondering how you are addressing the impossibility of preventing corrosion, well failure, spills, leaks, and accidents, especially given that every single parcel you previously sought to lease is underlain with abandoned mines?

To quote from Representative Debbie Phillips’ letter to Anne Carey yesterday, “According to the U.S. Forest Service groundwater policy and guidance documents, the Wayne National Forest has the responsibility to protect groundwater and drinking water supplies that may be affected by its activities. I ask that you carefully consider the impacts of these activities through an Environmental Impact Study.”

Forest Service is required to assess potential economic impacts before undertaking any significant action. The socioeconomic study done as required for the Wayne’s last Forest Plan does not evaluate economic impacts of past or future mining, drilling or industrialization of the Forest. There is no mention of acid mine corrosion’s threats to drinking water or of air pollution’s economic impacts on adjacent communities.

Air pollution from fracking must be evaluated –– 23 tons of volatile organics per well, according to USEPA–200 times the levels if not fracked–– and high levels of methane and particulates, making shale extraction dirtier than coal for greenhouse emissions. How are you assessing the impacts—environmental and economic—of this pollution locally and in relation to climate change?

Spills, explosions, and truck accidents happen frequently. Each frack requires up to 1500 trucks and a half-million pounds of concentrated chemicals and hauling out the more than ten million gallons of toxic waste liquid and sludge. Thousands of cases of contamination have occurred with significant public health and environmental costs. No lease stipulations, Ohio or BLM regulations or post-leasing site-specific EISes can protect against these impacts. They must be evaluated before any further leasing is authorized.

If you release any further lands to the BLM, you will be giving up your power to help protect our community drinking water, economy, safety and wellbeing. You have clear authority to say NO to leasing and to consider a ban as one alternative in an EIS, as other National Forest Supervisors have done. Or you can just say no to further leasing and wait until you do have the budget for an EIS. These are clearly the only appropriate choices. We’re fine either way.