URGENT: E-mail Army Corps TODAY re proposed frackwaste barge dock in Meigs County!

UPDATE: COMMENT PERIOD EXTENDED TO Aug. 24.  Model comments HERE and abbreviated ones here. Feel free to use! Or write acfanohio AT gmail.com for copy in Word.

Updated blog post here.

Please tell the US Army Corps of Engineers NO!! to a frackwaste barge dock on the Ohio River in Meigs County!

Send comments to Project Manager Teresa Spagna (teresa.d.spagna@usace.army.milto object to a permit for Texas frackwaste company GreenHunter for a frackwaste barge dock on the Ohio River in Meigs County, Ohio.Include RE: LRH 2013-848-OHR in the e-mail subject line. Please include your county and state of residence. 

SAMPLE E-MAIL or use these model comments for more detail and citations!
1. I object to this dangerous proposal, which threatens the drinking water of millions who rely on Ohio River drinking water, with millions of gallons of hazardous, radioactive frackwastes that will be unloaded and stored at this site daily and then shipped by truck to be dumped throughout the region.
2. The public notice and comment period were inadequate and illegal. The public notice must be re-done with adequate notice of electronic submission options, proper local media notice throughout communities in the region, and a new and longer comment period provided to allow the public throughout the eleven-state affected region adequate time to learn about and comment knowledgeably on this potentially devastating project. 
3. There must be an Environmental Impact Statement that the public can see and comment on before further consideration of this massive and significant federal project. Expected and unexpected potential impacts on air and water, including climate change, must be evaluated and made public.
4. This proposal warrants public hearings with proper public notice throughout the eleven adjacent and downstream states that will be directly impacted by this project.
5. The proposal should be pulled for as long as barging on the Ohio River is not legal. This proposal’s consideration at this time will bias the U.S. Coast Guard decision on approval of barging liquid frack waste.
Sincerely,
NAME
COUNTY and STATE of residence

See also attorney Terry Lodge’s comments to Corps with extensive legal arguments and endorsing organizations, submitted 7-28-14.

Army Corps notice at: 
Thanks to all commenters. Keep them coming! And feel free to send ADDITIONAL comments with more detail, even if you sent comments in last month.

Background and talking points:

The proposal by GreenHunter, a Texas-based frackwaste company, is to build a barge off-loading facility on the Ohio River in Portland, Meigs County. The dock would unload as much as 1 million barrels, or 42 million gallons of frack waste at once. After storage in aboveground tanks, the waste will be trucked to injection wells around the region. Barging of liquid frack waste has not been approved by the U.S. Coast Guard, which received as many as 60,000 public comments opposing the proposal.

The dock proposal has not been given official notice in state or local media. The online notice posted by the Corps June 27 specifies that public comments must be hard copies and received at the Corps’ Huntington office by July 28, which has, due to over 340 comments submitted, been extended to Aug. 24. Also, a subsequent verbal and written statement by Teresa Spagna, Project Manager with the Corps, assures us that E-MAIL COMMENTS ARE ACCEPTABLE.

Ohio has experienced TWO fracking explosions and fires this summer, one in Monroe County in which twenty fracking trucks burned for a week and which led to a “significant fishkill,” according to ODNR, and another in which a frackwaste truck at Envirotank’s Belpre facility exploded and burned three men. One remained in critical condition as of July 3. Both explosions involved transfers of hydrocarbon-laden frack liquids. Imagine an explosion from abarge carrying a half-million gallons of frackwaste at a site that is storing hundreds of thousands of gallons of this toxic radioactive waste. What would a spark igniting an off-loading bargeful with a half-million gallons of flammable frackwaste do to the riverside and downstream communities and the 5 million people who drink this water? 

This proposal affects all Ohioans and the region — it would open the floodgates to GreenHunter and other corporations that have no stake in Ohioans’ health and communities. Has ODNR ever said ‘no’ to an injection well permit? NO! (Ohio permits injection well in days, compared to states under USEPA permitting requirements, which can take years to permit. )

Please e-mail Corps Project Manager Teresa Spagna (teresa.d.spagna@usace.army.mil) to object to the proposal, request an extension of the comment period to October 31, and ask the Corps to hold a public hearing. Comments are due Aug. 24. 

RE: LRH 2013-848-OHR must be included in the e-mail subject line.

Extensive model comments with citations here.  Or feel free to use the following TALKING POINTS for your comments.

1. Since the Coast Guard has not ruled on the transporting of liquid frack waste on the Ohio River, such barge traffic on the river is illegal at this time. Preparing a huge transport terminal creates bias and affects the Coast Guard’s decision.

2. No Environmental Impact Assessment or Statement has been conducted by a nonbiased third party group. [Green Hunter itself has “retained the services of a malacologist to conduct a mussel survey (5 species are endangered)” –in other words, the corporation is paying for its own study of mussels only, the results of which will thus be influenced by the corporation.] The Army Corps of Engineers should order a complete EIS (Environmental Impacts Statement). The safety of the public and the environment requires knowledge of the extent to which the barge dock and its use by frack waste-transporting tanker barges will endanger the entire Ohio River system.  The EIS, by law, should concentrate on the key issues of the environment, public health, social impacts, and potential for long-term and/or catastrophic contamination to one of the nation’s greatest river resources.  The EIS should consider all relevant information with professionalism, rigor, fairness, objectivity, and impartiality, and should be subject to independent checks and verification. It should not be “bought” by the corporation seeking the permit and use of our river. 

3. The Army Corps of Engineers should deny a permit to Green Hunter for the construction of this barge dock for the following reasons:

A. The Corps should prevent an entire terminal to be completed and to go into operation with details of its construction and use maintained behind a screen of business confidentiality;

B. The Corps should prevent undue pressure placed upon the U.S. Coast Guard in considering whether to allow liquid frack waste transport on the Ohio River;

C. The Corps should consider the health and safety of a river whose water quality affects 11 states: Pennsylvania, Ohio, West Virginia, Kentucky, Indiana, Illinois, Tennessee, Missouri, and three lower tier southern states;

D. The Corps should provide more time to assess short and long term damages of fracking wastes, (many of which cannot be remediated) to trained scientists in all areas of energy exploration, water management, chemical and petrochemical fields, public health, and the environment as well as elected officials, government regulatory agencies, and citizens;

E. The Army Corps should understand the construction of the barge dock and its facility of pipelines, above-ground tanks, and other facility infrastructure as a clear path to expand the fracking industry—the GreenHunter barge dock project gives the green light to the transport of 105,000,000 gallons or more annually of toxic, flammable, and radioactive drilling wastes for injection into dozens of Ohio injection wells and solid waste disposal in area landfills;

F. The Corps should refuse to participate in a business plan to “offload” onto the public and the states the true costs of bulk shipping on inland waterways while only one corporation, GreenHunter, profits.

The Corps should reject this permit proposal until such time as Ohio has completed the rules process for facilities that will store, recycle, treat or dispose of liquid frack waste.  At this time Ohio has no rules regulating these facilities.

Send your comments to Teresa D. Spagna  teresa.d.spagna@usace.army.mil  

Subject: LRH 2013-848-OHR- Permit Application from GreenHunterMUST be included on subject line.  Please include your name, address, and county of residence in your e-mail.

Please copy to Senator Sherrod Brown. Contact form at brown.senate.gov/contact

See our statewide coalition press release at ecowatch.org or Ohio.com.

Athens County Fracking Action Network acfan.org,     acfanohio AT gmail.com

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