OGAP_Fracking_Letter_to_EPA_2002.pdf

Oil Gas Accountability Project P.O. Box 1102 863 1/2 Main Avenue Durango, Colorado 81302-1102 970-259-3353; Fax: 970-259-7514 October 28, 2002 Joan Harrigan-Farrelly, Chief Underground Injection Control, Prevention Program Office of Ground Water and Drinking Water Environmental Protection Agency Water Docket ID No. W-01-09-II 1200 Pennsylvania Ave. NW Washington, DC 20460 Email address: OW-Docket@epa.gov Dear Ms. Harrigan-Farrelly, The Oil Gas Accountability Project (OGAP) and undersigned groups appreciate the opportunity to submit comments on the Environmental Protection Agency’s (EPA) draft study report Evaluation of Impacts to Underground Sources of Drinking Water by Hydraulic Fracturing of Coalbed Methane Reservoirs. OGAP is a non-profit organization formed in 1999 to reduce and prevent the social, economic and environmental problems caused by oil and gas development. OGAP brings together more than 100 organizations across the country to advocate for greater corporate and governmental accountability, responsibility and respect for people and places in the course of oil and gas development. Formerly the Citizens Oil Gas Support Center, OGAP’s September 14, 1999 letter citing citizen complaints about hydraulic fracturing operations helped catalyze the EPA’s decision to launch this study. OGAP and the public interest organizations listed below are very concerned about the potential that toxic and cancer-causing chemicals used in hydraulic fracturing fluids have for contaminating underground sources of drinking water (USDW). In just the past fifteen years, thousands of coalbed methane (CBM) wells have been drilled in Alabama, Colorado, Montana, New Mexico, Utah, Virginia and Wyoming. Today, tens of thousands of new CBM wells are proposed for public, private, and tribal lands across the country. Once contamination of ground water has occurred, it is often impossible to mitigate the damages. A precautionary approach is the most reliable way to protect o