Assessing shale production honestly and accurately requires that all externalities, or created peripheral costs, be examined in a circumspect manner. It is imprudent, indeed stupid, to consider oil and gas projects without also considering the externalities which inevitably arise due to its heavy industrial nature. A careful look at costs such as road damages are certainly warranted but road damages are not the only externality with shales. Regions heavily engaged in shale production are now experiencing skyrocketing costs directly attributable to oil and gas production which are significantly outstripping revenues provided by extraction. These costs not only include road damages but also health impact costs and loss of crops. Very little has been said about such costs in the giddy statements made about shales. In fact, it would seem that the states which embraced shales early clearly did not conduct proper due diligence on the activities that they were green lighting. All of them, including the state of Texas which has a long history of dealing with oil and gas, have been caught completely unaware by these skyrocketing costs. Road repairs alone are now estimated, in some cases, to be multiples of what states are taking in from severance tax revenue. And road repairs are only one externality of shales.

The American Lung Association (ALA) quantified the health costs of air pollution from nitrogen oxides (NOx) and volatile organic compounds (VOC). These are two primary constituents of ozone. ALA estimates that the impact of such pollutants on the health of the people who live in regions where ozone is prolific comes to about $1648 per ton of NOx and VOC’s (2010 dollars).

The shale industry emits significant amounts of NOx and VOC’s in their day to day operations. In fact, when shale comes to town, it becomes one of the primary polluters. In Texas, the Texas Commission on Environmental Quality (TCEQ) studied air emissions from gas drilling operations in the Barnett shale region. In December 2011, TCEQ quietly submitted a report to the US EPA which confirmed that gas drilling operations in the region were producing significantly more VOC’s than all the on road mobile sources in this large metropolitan area (DFW). TCEQ estimated that gas drilling accounts for approximately 121 tons per day of NOx and VOC’s. That equates to about $202,000 per day or $73,000,000 per annum. Just for the Barnett region.

In Arkansas, emissions from shale gas production in 2008 were estimated by the Arkansas Department of Environmental Quality to be approximately 5979 tons per annum. In a mere four years (2012), emissions had grown to approximately 20,347 tons per year based on current extrapolations. This means that health costs soared from $450,000 to $33,500,000. And this annual expense is not covered by the industry that caused it.

In the Marcellus shale in Pennsylvania, the Department of Environmental Protection (DEP) estimated NOx and VOC emissions from shale production in 2011 at 19,300 tons per year. That translates into health costs of nearly $32,000,000 per annum. Again, none of the costs are covered by the industry that perpetrated it.

Further, much of these calculations from the various state regulatory agencies are based on self reported emissions inventories provided by industry. Unfortunately, states simply do not have the man power or resources to adequately check and verify such estimates. Because self reporting is suspect by its very nature, particularly when done by an industry that stands to gain monetarily through underestimation, it stands to reason that these costs could conceivably be much higher. For instance, industry self reported their methane emissions in Colorado and claimed in inventories that they never exceeded 2%. But the University of Colorado, Boulder and NOAA conducted a three year study on gas fields north of Denver and found that emissions were running about 6%. They then found emissions from a gas field in Utah running about 9%. So self reporting, for obvious reasons, has its issues.

Add these health impact costs to the estimates of road damages and the taxpayers burden continues to grow exponentially. Moreover, ozone also affects crop production. Cumulatively for the Barnett, Fayetteville and Marcellus, based on very conservative estimates, we can add another $26,000,000 on to the businesses of the region for crop losses and damages.

And, yes, that would be businesses other than the one that created the problem.

Does industry think that it has a responsibility to cover the costs or take responsibility?

When a paper issued by the Houston Advanced Research Center (HARC) was released last October it caused quite a stir. HARC scientists concluded that significant levels of formaldehyde, a known human carcinogen and precursor for ozone, were being emitted from gas operations. This is one of the primary reasons that the remote Jonah-Pinedale gas field found itself with ozone spikes that were higher than the worst day recorded in the City of Los Angeles.

The Texas Pipeline Association (TPA) made the following statement upon perusal of HARC’s paper:

“TPA and its members desire to be good stewards of our environment and are not opposed to regulation grounded in good and supportable scientific bases. The technical paper does not provide that type of support.”

Really?

This is an interesting interpretation by TPA if only for the following reason. The Chairman Emeritus and Founder of HARC, the entity that conducted and released the paper, is none other than George Mitchell. It was Mitchell Energy that perfected the technology of horizontal drilling and hydraulic fracture stimulation more popularly known as “fracking”. The current Chair of HARC is John Butler who also serves on the Board of Anadarko Petroleum. Other industry executives serve as well. It becomes a bit tricky to dispute findings from an entity whose board reads like a “who’s who” of energy academia and oil and gas.

Nevertheless, TPA stuck to its guns and stated:

“…the four significant problems identified…effectively render the conclusions meaningless”.

Billions of dollars in road repairs, tens of millions of dollars every year in health costs and agricultural damage is anything but meaningless. Unless of course, you consider privatizing profits and socializing damages an ethical way to do business.

http://energypolicyforum.org/2013/04/03/shale-externalities-health-impact-costs/

Albany, NY – Hundreds of medical professionals, health organizations, environmental, national and statewide leaders, and a hundred and fifty elected officials released a letter today calling on Governor Cuomo to let three public health studies cited by New York State Department of Health (DOH) Commissioner Nirav Shah conclude, open the state’s health review to public participation, and to conduct a New York-specific Health Impact Assessment before making a decision on fracking.

Signatories to the letter include health organizations such as the American Academy of Pediatrics, District ll New York State, American Lung Association in New York, Clean Air Council, Breast Cancer Action, and Concerned Health Professionals of NY. More than a hundred medical and scientific experts including Jerome A. Paulson MD FAAP, Director of the Mid-Atlantic Center for Children’s Health & the Environment, Theo Colborn PhD, President The Endocrine Disruption Exchange, and George Woodwell PhD, NRDC Distinguished Scientist and founder of Woods Hole Research Center. Additionally, 150 elected officials are among the signatories, many environmental and public interest groups including Environmental Advocates of New York, Sierra Club Atlantic Chapter, 350.org, Working Families Party, and Citizens Campaign for the Environment, and notable individuals including Lois Gibbs, Gloria Steinem, Pete Seeger, Bill McKibben, Melissa Leo, and Mark Ruffalo.

Commissioner Shah, whose agency is conducting a review of fracking’s public health impacts, recently announced that he needed more time for his agency to finish its review. Shah also said “the time to ensure the impacts on public health are considered is before a state permits drilling,” and cited three studies – U.S. EPA’s study, Geisinger Health Systems’ study, and the University of Pennsylvania’s (in collaboration with scientists from Columbia, Johns Hopkins, Harvard and University of North Carolina) study – as representing the first comprehensive studies of fracking’s health impacts at either the federal or state level.

Making a decision on fracking in New York State without waiting for these studies’ results makes no sense. There is limited data and knowledge about exposure pathways or why people across the country are reporting illness from fracking. More study is necessary to understand these issues, as well as New York-specific concerns, in order to make an informed decision.

“We appreciate Governor Cuomo calling a ‘time out’ so that long-standing questions about health effects can be answered,” said Sandra Steingraber a biologist and founder of Concerned Health Professionals of New York.  “As Commissioner Shah noted, there are three comprehensive studies being undertaken.  New York should wait for those studies and open its own health study up to public comment.”

“On behalf of the over 6000 pediatricians in New York state that take care of our most valuable resource, our children, I would like to applaud the Governor for allowing the scientific process to be completed before issuing any permits to allow for high volume hydraulic fracturing,” said George Dunkel, Executive Director of American Academy of Pediatrics, District II/NY. “I need to stress that the children are not just small adults—children are affected much more acutely and are more vulnerable to environmental toxins than adults.  We thank the Governor for allowing this most important process to be completed and for his commitment to the children of New York.”

“Too many New Yorkers get sick and die prematurely because air pollution levels are too high,” said Michael Seilback Vice President of Public Policy and Communications at the American Lung Association in New York.  “High volume hydrofracking has the potential to  make things worse – worse for those living in areas where thousands of diesel trucks will commute daily and worse for the thousands of New Yorkers who will be exposed to deadly emissions from drilling in areas that have not previously had elevated levels of air pollution.  While we’ve made tremendous progress in cleaning our air, 3.2 million New Yorkers still live in areas where unhealthy air threatens their lives and health, as shown in the Lung Association’s State of the Air 2012 report.  We are asking Governor Cuomo to wait until experts have finished examining the science before making any decisions.  Please, make no decision until health questions are answered and health concerns are addressed: the lungs of millions of New Yorkers depend on it.”

“The medical community of New York has been calling for comprehensive health studies for two years, and these should be completed prior to the decision on shale gas extraction.  We are grateful that the Governor agrees with Dr. Shah to make public health the priority,” said Dr. Larysa Dyrszka.  “To accomplish that, it is critically important that the health review is put on hold until the studies Dr. Shah cites are completed and fully reviewed.  Further, there must be public comment and participation, and at least one public hearing on the current NY State health review.  And finally, all the concerns raised by the public and the medical community need to be addressed as part of a comprehensive and transparent Health Impact Assessment.”

“The gas industry has spent millions of dollars to bully Governor Cuomo into supporting its companies’ bottom line by opening the state to fracking,” said Katherine Nadeau, Water & Natural Resources Program Director at Environmental Advocates of New York.  “But the Governor stood up to the gas giants on behalf of average New Yorkers who have serious unanswered questions about fracking’s safety.   We look forward to an open public process that will undoubtedly accompany a health study, as the only way to answer the tough questions Dr. Shah raised is by shedding light on the state’s deliberations.”

To date, the Cuomo administration has not done a health study of fracking. Instead, three outside experts have been hired to help with a narrow, internal review written by the state. The administration has not released any substantial information to the public on its review and the medical and scientific community has not had an opportunity to comment or contribute.

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View the February 27, 2013 Letter to Governor Cuomo

(Albany) – Concerned Health Professionals of NY released a joint statement declaring New York State’s health impact assessment grossly inadequate and flawed. Following completion of his analysis of the state’s health review, outside reviewer, Richard Jackson, gave an hour-long webinar about health impacts in which he demonstrates an alarming lack of understanding about major issues relevant to fracking’s health impacts in New York State. The health experts released a written annotated transcript (attached) of Jackson’s webinar that illustrates gaps in Jackson’s knowledge of key issues. The annotations were written by Larysa Dyrszka, MD, Concerned Health Professionals of NY; Anthony Ingraffea, PhD, PE, Dwight C. Baum Professor of Engineering, Cornell University; Kathleen Nolan, MD, MSL, Catskill Mountainkeeper; and Sandra Steingraber, PhD, Distinguished Scholar in Residence, Ithaca College and founder, Concerned Health Professionals of New York.

Jackson’s lack of knowledge – coming after finishing his analysis of New York’s health review – undermines the credibility of the secret internal assessment the state has done. The assessment does not meet Governor Cuomo’s promise to conduct the most comprehensive health review ever and it is inadequate to ensure the protection of New Yorkers. The coalition calls on Governor Cuomo to open every facet of the state’s health review for public participation and comment, and calls on the governor not to make any decision about fracking or move forward in any way. 

Among the issues are:

• Jackson praises as “excellent” a Pennsylvania study that has long been discredited as industry propaganda. Additionally the authors of that report are two of the same researchers who later authored the fraudulent report that prompted the University of Buffalo to shut down its Shale Resources and Society Institute last November.
• Jackson says that he is “not in a position to debate” whether reports of water contamination from drilling and fracking operations are true or not. Why not? The information has been quantified, verified, and this should be a relevant data-based analysis.
• Jackson mistakenly says that fracking wastewater is no longer discharged into rivers and streams. The practice goes on in other states and would be allowed with a special permit in New York State.
• Jackson is misinformed about the contribution of shale gas extraction to climate change, and bases his statements on outdated information. For instance, Jackson says that “Methane is a greenhouse gas that aggravates global warming about 15 times more effectively than CO2.” This is incorrect information. Also see here. 

Along with the annotated transcript, Dr. Nolan and Dr. Steingraber of Concerned Health Professionals of NY released this statement:

“Richard Jackson’s ignorance of critical issues related to the health impacts of fracking demonstrates the inadequacy of New York State’s limited, secret, internal health review. The cursory and poorly informed content of Jackson’s January 9, 2012 one-hour, national webinar presentation undermines the credibility of the state’s review process, as it suggests that the materials provided to Dr. Jackson were dated and poorly sourced, rather than gleaned from up-to-the-minute peer-reviewed and independent scholarly reports. By his own account, Jackson gave the presentation, titled “Hydraulic Fracturing Impacts Human Health: Public Health Strategies to Reduce the Risks” after he finished his analysis of New York State’s health review.

“In his remarks, Jackson demonstrates limited and misinformed perspectives about many of the most significant issues around fracking, at one point praising as ‘excellent’ a Pennsylvania study that has been long discredited as industry propaganda and that was written by two of the same researchers who later authored the fraudulent report that prompted the University of Buffalo last November to shutter its Shale Resources and Society Institute.  At another point, Jackson says that he is ‘not in a position to debate’ whether reports of water contamination from drilling and fracking operations are true or not. In speaking about the discharge of fracking waste water into rivers and streams, he says, ‘that doesn’t go on any longer, I’m told,’ although the practice is common in other states with ongoing fracking operations and, in fact, would be allowed, with a special permit, under the draft regulations for fracking recently released in New York State. Jackson’s understanding of the contribution of shale gas extraction to climate change is incomplete and based on old research.

“For Jackson to be misinformed about critical issues after finishing his review demonstrates why allowing New York State’s health review to be narrow in scope and shrouded in secrecy is woefully inadequate. This is underscored by gaps in Richard Jackson’s knowledge about the myriad complicated pathways of potential exposure, well failures, rates of methane leakage, earthquakes, and hazardous air pollutants. Governor Cuomo has promised the citizens of New York the most comprehensive health review ever done, and New Yorkers have been told that the outside consultants would review it in great detail in order to ensure the safety of their families. There is now no doubt that the state’s review to date does not meet this standard. As Dr. Jackson himself says: ‘So big take away, I do think that research into safer and healthier energy sources and research into the health impacts of these sources and doing all cost accounting and full health impact assessment of our energy sources is what we need in the United States.’

“What Jackson calls for nationally, we need in New York. The Department of Health absolutely must open its health review for public participation and comment. Governor Cuomo must keep his promise to protect the health of New Yorkers. At this time there can be no decision about fracking, and the state cannot move forward in any way.” 

Gannett News reporter Jon Campbell revealed emails from Richard Jackson showing that he finished his review well before he gave this January 9, 2013 webinar. See the February 8, 2013 article by Campbell titled “Health consultants made fracking recommendations weeks ago.”

Dr. Kathleen Nolan, MD, MLS, Catskill Mountainkeeper, said,  “If New York State were to move forward based on the level of understanding of the health impacts of fracking as revealed in this presentation, New York State would be in big trouble.”

Sandra Steingraber, PhD, Concerned Health Professionals of New York, said, “As the day for the governor’s decision looms, we continue to be in the dark.  On the one hand we are told by DEC Commissioner Martens that the health review is determinative. On the other hand, we are told by DOH Commissioner Shah that the charge given the reviewers was very narrow. We don’t know what that narrow charge was nor what documents they received to review. And now one of the reviewers—a public health scientist whom I greatly admire—shows, during a public seminar, a very shaky grasp of the fundamentals of fracking. I’m not sleeping well.”

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Annotated Transcript of “Hydraulic Fracturing Impacts Human Health: Public Health Strategies to Reduce the Risks”

A webinar by Richard J. Jackson, MD, Professor and Chair, Environmental Health Sciences, UCLA School of Public Health

(Albany)—Following the November 27 launch of the Concerned Health Professionals of NY initiative, the group of medical experts released an eight-minute video appeal to the three independent health experts contracted by the Department of Health to review the DOH’s own internal health review of fracking. The Concerned Health Professionals of NY video summarizes a number of emerging, unresolved health concerns posed by fracking and the reasons that New York’s public health experts have insisted to Governor Cuomo that the enormously important task of assessing the impact of fracking on New Yorkers’ health requires a transparent, comprehensive Health Impact Assessment with full public participation. A hasty, secretive review is no substitute.  Only when all public health and environmental concerns associated with fracking have been fully resolved should Governor Cuomo make a decision whether or not to lift the state’s current moratorium and allow fracking in New York State.

To date, no one in the public or medical community has seen the DEC’s review of health impacts, nor has the Cuomo Administration shared details regarding who or what has been involved in its development and execution. As the three independent reviewers examine the DEC’s findings about the impacts of fracking on public health, the public and the medical and scientific community are still in the dark, and no one knows what the process or opportunity for input will be. Yet one of the contracted experts, Lynn Goldman made statements to the press that she has a December 3rd, 2012 deadline to complete her work even though she had signed a contract only 10 days prior and had not yet seen the DOH’s review. And on Thursday, it was revealed that the contract of another of the three reviewers specifies a pay rate of $480 per hour with a $12,000 cap, which allows for only 25 hours of work.

In a personal appeal in the video, Sandra Steingraber, Ph.D., biologist and Distinguished Scholar in Residence, Ithaca College, describes how her family’s fate hangs in the balance of the health review’s findings, and yet she has no input into the study’s design.  “We all know each other, the four of us—the three panelists and myself. We go to the same conferences.  We have served on some of the same panels. We’ve won some of the same awards. . . .Now you have access to documents and data that I do not have. Now I am your data. So I’m wondering what you will do. I’m wondering what our relationship is. These documents and data profoundly affect me not only as a biologist and an environmental health scientist but as a mother of a child with asthma.”

Larysa Dyrszka, M.D., retired pediatrician and advocate for children’s right to health, describes for the reviewers the gaps and gross inadequacies of the supplemental Generic Environmental Impact Statement, “The issues that we have called to the DEC’s attention in 80,000 comments include many health impacts, things that were not addressed in the SGEIS, such as radioactivity, community impacts, worker safety. There are pathways of exposure that need to be identified even though the DEC feels that their measures are going to be protective enough that it won’t happen. Well, accidents happen.”

The six health experts featured in the video explain a number of the unresolved health impacts of fracking, including pathways of exposure.

Dr. David O. Carpenter, Director of of the Institute for Health & Environment at the University at Albany, requests that the reviewers consider exposures to radioactivity, “In some of these fracking fluids, we see levels of radioactivity from radium 226 that are thousands of times higher than the standard for drinking water and that are hundreds of times higher than the standards for release of wastewater. But wastewater treatment plants in general do not remove radioactive materials, so then it gets dumped into the local river or stream, and often the intake for the drinking water is downstream from where the wastewater goes in. The big concern is that we will end up with radiation exposure from drinking water that people don’t even know about.”

Margaret Roberts, representing the New York State Breast Cancer Network, urges to reviewers to address the link between diesel exhaust and breast cancer risk. “With fracking there is a 24 hour cycle of constant truck traffic which creates extensive pollution around fracking sites, and there are studies that strongly suggest that women who are exposed to PAH’s in air pollution when they are pregnant or when their children are young, the children will grow up to be at higher risk of cancer later on.”

Concerned Health Professionals of NY is alarmed that the DEC’s release of revised regulations and the accompanying 90-day extension means that fracking is being rushed forward. Putting out revised regulations before the DOH’s own panel of health experts have had a chance to weigh in indicates that the regulations are being based on political expediency, not science. Fracking poses potentially severe public health impacts. Only the most rigorous science must drive the decision, not arbitrary deadlines. This is no place for rush jobs or secrecy. That’s why only an independent, comprehensive Health Impact Assessment is sufficient, which would include public participation, transparency, and follows procedures recognized by leading medical organizations such as the World Health Organization.

Dr. David Carpenter insists that any study of fracking’s health consequences must quantify the associated medical costs. “Economic development at the expense of the health of the public is not a net gain, it’s a net loss because of the costs of the health care, the costs of loss of years of life, the costs of all the medications one must take, and therefore it is extremely important that we have this risk / benefit analysis done right.”

Sandra Steingraber, PhD, describes the conundrum of New York’s environmental health scientists and doctors who live in upstate communities targeted by gas drillers. “We deal with data and evidence, and now we are living in a place that could become a study site for an environmental travesty. We could become the data points in an uncontrolled human experience.  If we massively industrialize our rural landscape here in NY and fill it up with carcinogens, fill it up with endocrine disrupting chemicals, and lay down a blanket of smog, then we set in motion the wheels of a human experiment. And now we’re the subjects, the un-consenting subjects, of that experiment.”

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On November 27, 2012, Philip Landrigan, MD, Chair of the Dept. of Preventive Medicine and Director, Children’s Environmental Health Center at Mt. Sinai School of Medicine released this statement:

“By insisting on a comprehensive health impact assessment as a precondition for a decision to permit or prohibit hydraulic fracturing in our state, Concerned Health Professionals of New York is upholding the fundamental principles of preventive medicine. The unique vulnerability of children to chemical contaminants and air pollution – of the kind we know are associated with drilling and fracking operations – means that we must undertake the most thorough investigation and seek the input of many experts. This is no time for secrecy. Members of New York’s medical community must have access to the documents that are now under review by the team of outside reviewers. The public – who are being asked to assume risks of fracking – must likewise have input to the scientific process that is judging those risks.”

The new initiative, Concerned Health Professionals of New York, seeks to provide the public, press, elected officials and other health professionals with information about the health risks posed by fracking as well as a history of how hundreds of health professionals have been calling on Governor Cuomo to conduct a comprehensive Health Impacts Assessment to adequately study the impact of fracking on public health before making a decision whether or not to lift the state’s current moratorium and allow fracking in New York State.

Larysa Dyrszka, M.D., retired pediatrician and advocate for children’s right to health, said, “As a tool for understanding the health risks of a polluting industry, there is no substitute for a comprehensive, transparent health impact assessment with public input.  We know that, and we know the advisory panel knows that.  But because we don’t  know what documents the advisors will be allowed to ‘review,’ we’ve compiled this website of information for their further consideration.”

The health professionals detailed a series of health concerns that they believe cannot be avoided, including radioactivity, dangerous air pollution, and water contamination.

Sandra Steingraber, Ph.D., biologist and Distinguished Scholar in Residence, Ithaca College, said, “A pall of ignorance hangs over fracking.  Emissions data, monitoring data, exposure data–these are the things you need in order to judge health effects, and where are they?  Held hostage by non-disclosure agreements, gag orders, and right-to-know exemptions.  We feel certain that these three panelists will see, as we do, the huge data gaps–as well as the emerging signals of harm in other states where fracking operations are ongoing.”

In September, the Department of Environmental Conservation announced that they had conducted their own internal health review and that it would be reviewed the Department of Health. The Department of Health recently announced that three independent health experts had been contracted to review the Department of Health’s internal review. One of the experts, Lynn Goldman made statements to the press that she has a December 3rd, 2012 deadline to complete her work even though she had signed a contract only 10 days prior and had not yet seen the DOH’s review.

“How can the state of New York ask three outstanding public health experts to evaluate the many risks of fracking–radiation, diesel exhaust, silica dust, traffic noise, toxic spills–and give them a few weeks to do the job?” said Dr. David O. Carpenter.  “It’s ridiculous.”

Health experts also commented on the November 29th State Administrative Procedure Act (SAPA) deadline and called on Governor Cuomo to not commit to the arbitrary deadline of a 90 day extension but instead allow science and public participation to guide the process.

“With the health and well-being of millions of New Yorkers at stake, we are asking Governor Cuomo to allow for science and a public process to guide his decision on whether or not to lift the state’s current moratorium on fracking and not hold to the arbitrary deadline of a 90 day extension,” said Sandra Steingraber, Ph.D. “Our efforts today are to renew the call for a comprehensive Health Impact Assessment, which will allow for New York’s State’s medical community to participate in a transparent public process.”

To date, no one in the public or medical community has seen the DEC’s review of health impacts, nor has the Cuomo Administration shared details regarding who or what has been involved in its development and execution. As the three researchers examine the DEC’s findings about the impacts of fracking on public health, the public and the medical and scientific community are still in the dark and no one knows what the process or opportunity for input will be. The health experts emphasized at their press conference that only a comprehensive Health Impact Assessment is sufficient, which would include public participation, transparency, and follows procedures recognized by leading medical organizations such as the World Health Organization.

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