Community members in contact with Wayne National Forest officials regarding their review process of deep-shale high-volume horizontal drilling and fracturing (HVHF) have been alarmed to hear them defending plans to resubmit parcels to the BLM. This would be unconscionable. Some key issues:
1. The National Environmental Policy Act (NEPA) and the new Forest Service Planning Rule (which took effect May 9) require that the Wayne consider potential impacts to the region's human environment, including the local economy, from any significant action in an Environmental Impact Statement (EIS) with full public input. The 2006 Forest Plan EIS did not consider deep-shale HVHF, so a new EIS is clearly warranted. Wayne officials are saying they don't want to do an EIS because they'll have to do one for their next Forest Plan. This is irrelevant and insulting to our community, which has grave concerns over impacts to our region's water, air and economy. Any leasing will mean a later EIS will be useless to prevent drilling. Any later EIS will only be able to address the "how" and not the "whether." Having a say in how our aquifer gets drilled is like choosing how one is to be shot.
2. Wayne officials have been stating that because only a few of the vertical wells predicted to be developed in the 2006 Forest Plan have been developed and because fewer horizontal wells are developed per area, the impact won't be significant. This is like saying that because they planned to build 50 rowboats and only built 10 that it's okay to build some Titanics instead. ANY Titanics — horizontal deep-shale drilling and hydraulic fracturing — will have significant impacts that have NOT been evaluated.
3. According to U.S. Forest Service groundwater policy and guidance documents, the Wayne has the responsibility to protect groundwater and drinking water supplies. Some 70,000 people depend on the shallow, highly permeable aquifer that lies along four Wayne parcels and the Hocking River and is the sole source for Nelsonville, LeAx, Burr Oak Regional Water District and Athens city. Abandoned mines underlie ALL the river parcels at issue. Acid mine drainage corrodes steel and concrete in a matter of decades. Spills, explosions, truck accidents and equipment failures have led to thousands of cases of HVHF contamination with significant public health and environmental costs borne by communities. The Wayne has NOT evaluated these costs. Although the Wayne comprises only a fraction of Athens County, it is an economically and environmentally significant area. No lease stipulations or Ohio BMPs ["best management practices"– sic!] can protect against these impacts.
4. The Wayne 2004 socioeconomic assessment for the 2006 Plan did not evaluate public health, recreation, local food or other socioeconomic COSTS of past or future mining, drilling or industrialization of the national forest. There is no mention of acid mine drainage corrosion threats to drinking water by fracking, since fracking is not evaluated. Hocking Valley Scenic Railway and Hockhocking Adena Bikeway (Athens County's #1 and 2 tourist attractions) are not mentioned. Nor are Nelsonville Public Square or Robbins Crossing. All are extremely vulnerable to air and water pollution, noise and truck traffic from fracking the Wayne. These cannot be prevented by lease stipulations or post-leasing "site-specific" EIS.
5. Wayne Supervisor Anne Cary points to the patchwork map of Wayne mineral ownership and suggests the Wayne is helpless in the face of private ownership. This ignores that the Wayne must evaluate regional and cumulative impacts on all its lands, whether or not it owns "minerals" and especially on lands for which it does.
6. Gary Chauncey, Wayne public information officer, asks why we don't trust ODNR. Wayne officials reference ODNR guidelines for fracking state lands, which allow well pads 300 feet from campgrounds! Yet one well vents 23 tons of volatile organic compounds, unrestricted by Ohio law. Comments by Natural Resources Defense Council on draft Ohio well regulations that "lack the minimum standards necessary for the protection of the public health, safety and environment, and (2) lag behind the state-of-the-art requirements in drilling technology, practice and engineering." Ohio grants "on-site inspector[s] with unlimited authority in approving remedial actions when unanticipated complications arise during well construction operations… to be exercised promptly at the site with only the information at hand…" Yet "the rules provide no training standards for Division inspectors…" Ohio rules don't meet American Petroleum Institute standards. Ohio does not consider environmental factors in approving wells.
7. The recent OU survey reveals strong community opposition to fracking: 75.2 percent of respondents felt their quality of life would be negatively impacted, 69 percent said fracking OU would not provide a long-term boost to the local economy, 75.9 percent predicted a negative or extremely negative impact on personal safety, and 85.1 percent responded it would have a negative to extremely negative impact on water.
8. If Anne Carey releases land to the BLM, she will be giving up her power, and ours, to protect our community drinking water, economy, safety and well-being. She will breach the public's trust if she cedes authority despite significant public concern, huge stakes and NO public input into the process.
Our water, air and economy cannot be protected with lease stipulations, ODNR rules or a public input process later. The public could not express its grave concerns in 2006. A new plan-level EIS pre-leasing must be done. Join us at Wayne Headquarters to tell this to officials Wednesday, May 23 at 4 p.m. Visit acfan.org for our petition, letter-writing and other info.
Editor's note: Heather Cantino of Athens is active in the Athens County Fracking Action Network.