The EPA's Scientific Advisory Panel on Hydraulic Fracturing Peep Show
There is no ending to the energy wars that have become culture wars and they have infested even ostensibly technocratic agencies of the government that ordinarily should be held above ideology. Not so in the imagery-loaded EPA under the Obama Administration.
The agency’s latest foray is the establishment of a 22-member Scientific Advisory Board (SAB) Panel, referred to as “Panel for Review of Hydraulic Fracturing Study Plan for Assessment of the Potential Impacts of Hydraulic Fracturing on Drinking Water Resources.” Now one would think that this is a noble undertaking but a look at the roster of the panelists, investigative approach, exclusivity and ramrod urgency would put this notion to immediate rest.
Certainly many of the review panelists are experts in their respective fields of ground water hydrology, toxicology, forestry, and public health, etc., but almost all have little to no experience in the well fracturing process and no understanding of current industry practices. The panel excludes outright any of the arguably most famous names on the subject: Holditch (author of 300 papers, author/editor of SPE Monograph on the subject), Meyer, Barree, Cleary, Smith (the creators of the four industry standard design softwares that could actually model fracture dimensions and fracture height) and myself, the author of 200 papers and five books on the subject. Presumably publications on the subject would be against the candidacy of these individuals as panelists, an outrageous presupposition that their technical prowess would render them to be industry shills.
The almost surely intentional absence of industry participation, except for briefly orchestrated public testimony, is to say the least, curious. Coupling the absence of industry experts with the study plan itself provides even greater insights.
Despite having thousands of wells to consider, EPA has held “stakeholder” meetings in which several handfuls of wells have been identified for their potential contamination to drinking water. Of these, four will receive forensic examination within the context of a hydraulic fracturing water life cycle, including water source and availability, chemical mixing, well injection, flowback and disposal.
Key drivers in selecting the four retrospective cases are focused much more on data availability and likeliness of identifying problems, rather than applicability in representing the normal range of fracturing outcomes. From these limited cases EPA expects to draw massive conclusions, stemming from a hurried, single year of ‘research’. Given that the research has not yet been awarded, one wonders if the answers are already foregone conclusions.
Other aspects of the study are equally worrisome; the entire report focuses on nanodarcy, such as shale, rock completely ignoring the fact that most wells are fracture stimulated upon completion, including those in high permeability environments. Presumably one villain frac treatment in shale condemns an entire industry practice regardless of any technical differences in the fracturing process.
Most panel members simply could not distinguish (or probably would not even care) whether any observed contamination could be the result of faulty well construction (a rare but real possibility) or some entirely mythical “subsurface communication” as suggested in silly documentaries like Gasland. Wellbore construction and the fracturing processes are not at all the same things, yet lack any separate commentary under the header “well injection’ in the flawed study plan. Only newly minted Ivy PhD’s in public policy (likely those who wrote this plan), or those pre-disposed against the production of any natural gas, would fail to make this distinction.
Another concern is the wholesale disregard for current State regulatory practices. The efficacy of existing regulations are not even considered in the EPA draft study plan, discounting the efforts that organizations such as STRONGER [State Review of Oil and Natural Gas Environmental Regulations, a non-profit, multi-stakeholder organization], have clearly played a unification and enforcement role at the State level. Their work is not considered as part of the proposed EPA Hydraulic Fracturing Study.
Even the outcomes of EPA modelers are misled. The study plan makes no mention of the hydraulic fracturing models developed by industry experts such as those noted herein, nor is there any mention of modeling with the use of microseismic post fracture morphology (fracturing height length) verifications from hundreds of treatments. Rather, esteemed modelers of the EPA will “assume” a fracture within the context of their subsurface hydrologic flow models, perhaps without any geological context. This assumed fracture may bear no resemblance whatsoever to the actual fractures resulting from a pumped treatment.
And the list goes on and on.
Let’s fast forward a year and imagine the results, assuming that EPA limits itself to study the four or so cases (out of hundreds of thousands) where suspicions may have arisen of water contamination either from natural gas production (unrelated to the fracturing itself, even if the well was fractured) or to the even rarer possibility of contamination because of fracturing fluid additives. Assuming that 3 out of 4 of these cases find some connection (the two Gasland examples were debunked) then one can see the headline: “EPA SAB finds that 75% of water contamination incidents were in fact caused by hydraulic fracturing,” clearly a hatchet job, a truism that conveniently ignores the incredible rarity of the three case out of hundreds of thousands wells that are hydraulically fractured and, perhaps exactly, satisfying the latent motives of the creators of the EPA SAB on hydraulic fracturing.
A finding that contamination can happen through an accidental defect in well construction, even if it has happened in one case in 100,000, is something that simply cannot be determined from limited retrospective case studies, and any single official “finding” would have only one effect: alarm unnecessarily the public and reinforce the opinions of those that already have opinions on either side of the issue.
There is a “peep show” quality to the whole affair, with EPA actions occurring within the public eye but only ‘glimpses’ of the real picture within. With the introduction of the phrase “area of evaluation” in the study plan, it becomes clear that the” show within” is to impose area of review studies around any hydraulically fractured well in the United States. Such regulatory authority could shift the “frac, no frac” decision from State authorities to the EPA, resulting in gas well drilling moratoriums similar to the drilling largess now experienced in the Gulf of Mexico.
To somebody that understands (and believes in) the importance of natural gas to the country’s welfare it is clear that only those predisposed against any hydraulic fracturing could be pleased with this study. The EPA panel has served their role in sanctifying this EPA hydraulic study plan, positioning researchers and other so-called experts to legitimize a clearly illegitimate and ideologically loaded attack on “fracking”, done by people that are predisposed against any natural gas production.
Rarely have intentions been more transparent.