From the Landward Side

Comments: Proposed Hydraulic Fracking Regulations

Judy Bell, from ONO affiliate FrackFree SA, sent comments to the Dept of Fisheries, Forestries and Environment. We include them as a summation of the risks of fracking facing our water-scarce land by the Gas Master Plan:

Fracking should be banned, as it cannot be deemed safe anywhere, anyhow.  The risk to lives and livelihoods from is our current reality – from the wildfires, the extremes of temperature, to the alternating floods and droughts, we have to leave the fossil fuels in the ground.  We have to reduce our greenhouse gas emissions while we learn to adapt to a planet which can no longer support our “business as usual” approach to human life on earth.  These are some of the facts.

1. Stranded Assets – there are cheaper alternative sources of energy which are less harmful to humans and the planet, we should no longer invest in wasteful, “white elephant” infrastructure. 
   • Fracking is currently banned in so many countries for so many reasons and the most pressing is that we are living with the impacts from the climate crisis, it is no longer a prediction and is accelerating as the planet heats from the extraction and use of fossil fuels. 
   • There is a global call for a world-wide ban on fracking.
   • Renewables are now cheaper than fossil fuels.
   • Solar panels on rooves put the power back into people hands.  The first detailed global assessment of the electricity generation potential of rooftop solar panels has revealed that the total global potential for electricity produced in this way exceeds all the energy used worldwide in 2018.  Energy sovereignty is an essential fundamental of the “Just Transition”.
   • DFFE has the mandate to protect our life support systems for current and future generations, but fracking will put us all at risk.  Banning fracking is the responsible thing to do.
2. Health – there are acute, chronic and latent impacts
   • Pennsylvania children living near unconventional oil and gas (UOG) developments at birth were two to three times more likely to be diagnosed with leukemia between the ages of 2 and 7 than those who did not live near this, after accounting for other factors that could influence cancer risk, a novel study from the Yale School of Public Health finds.  The registry-based study, published Aug. 17 2022 in the journal Environmental Health Perspectives, included nearly 2,500 Pennsylvania children, 405 of whom were diagnosed with acute lymphoblastic leukemia, the most common type of cancer in children.
   • New research documents for the first time the pollution of public water supplies caused by shale gas development, commonly known as fracking, and its negative impact of infant health.  These findings call for closer environmental regulation of the industry, as levels of chemicals found in drinking water often fall below regulatory thresholds. “In this study, we provide evidence that public drinking water quality has been compromised by shale gas development,” said Elaine Hill, Ph.D., an associate professor with the University of Rochester Departments of Public Health Sciences, Economics and Obstetrics & Gynecology.  “Our findings indicate that drilling near an infant’s public water source yields poorer birth outcomes and more fracking-related contaminants in public drinking water.”

Question: How will we deal with these additional health risks in our collapsing (and collapsed) public health system?

3. Water Use
   • Fracking consumes a massive amount of water. In the United States, the average can run between 1.5 million (5.7 million litres) and 9.7 million gallons (36.7 million litres) of water to frack a single well, according to the United States Geological Survey (USGS). The amount depends on a few factors, including the type of well and rock formation and a well can be fracked multiple times (up to 40 times!) over the entire length of the borehole.
   • Fracking also produces huge volumes of wastewater laced with cancer-causing chemicals, salts and naturally-occurring radioactive material that can cause earthquakes and contaminate aquifers when pumped underground.
   • In the US it was determined that fracking companies used 770% more water per well in 2016 than in 2011 across all the major producing regions.  The number of new fracking wells decreased as gas prices fell, but the amount of water used per well skyrocketed, with up to 1,440% more toxic wastewater generated in the first year of each new well’s production period by 2016.  The peer-reviewed research published in the journal Science Advances in 2018 raised new concerns that hydraulic fracturing, the controversial drilling technique used to extract oil and gas trapped deep in bedrock, imperils vital drinking water reserves. 
   • In regions where the warming climate is drying sources of fresh water, fracking intensifies pressure on an already-strained system while increasing the availability of fuels that cause greenhouse gas emissions, speeding up the rise in temperatures, extent and intensity of wildfires, destructive winds, floods and drought.
   • South Africa, a naturally water-scarce country and the 30th-driest in the world, is already feeling the pressure. It is predicted that the country’s water demand will outstrip supply by 2030.  We are always a dry, rainy season away from a drought and have many “dry” towns and now another metro facing “Day Zero”. El Nino is set to return in the medium term and we have already polluted so much of the water that is left, we definitely will not have enough to go around.

Question: Who will have to give up their right to water to enable hydraulic fracturing to take place?  Who will make this decision?

4. Sand Use
   • A lot of sand is needed in fracking – up to 10 000 tons of sand per well.
   • Frac sand is a high-purity quartz sand that is injected into wells to blast and hold open cracks in the shale rock layer during the fracking process. It is being mined intensively from sandstone deposits and with that comes a number of air, water, public health concerns. These include but are not limited to displacing agricultural lands and ecologically sensitive ecosystems, contaminating surface water and emitting silica sand into the air, which is a human health hazard.
   • Unsustainable sand mining is already putting incredible pressure on rivers, deltas and coasts in many parts of the world, resulting in river and beach erosion, lower water tables, salt water intrusion into aquifers and increased threats to freshwater and marine fisheries.  Excessive sand mining can alter the river bed, force the river to change course, erode banks and lead to flooding. It also destroys the habitat of aquatic animals and micro-organisms, besides affecting groundwater recharge.
   • In South Africa, the illegal extraction of sand from rivers can alter the course of a river and lead to an altered structure that may erode river banks and cause damage to vegetation and arable land. In addition, sedimentation can block channels and deny fish access to clean water.  The loss of biodiversity is critical at a time when we have already lost and are continuing to lose millions of species on which we rely to support our lives on earth.
   • The social impacts from sand mining include drowning in river “sand mining holes” especially children; suffocation in collapsing sand pits on land; use of child labour; injuries and fatalities from illegal sand mining “gang wars”; injuries and fatalities from trucks transporting sand; increase in crime from illegal mining’s temporary settlements, and so much more.

Question: from where will this sand be responsibly sourced, while avoiding further impacts (financial, environmental, social) from the existing land stripping and river mining?

5. Waste Generation
   • Drilling for methane and other fossil fuels is an energy-intensive process with many associated environmental costs. In addition to the gas that is produced through high volume hydraulic fracturing, the process generates a great deal of waste at the drill site. These waste products may include several dozen tons of drill cutting at every well that is directionally drilled, in addition to liner materials, contaminated soil, fracking fluid, and other substances that must be removed from the site.  
   • In 2018, Pennsylvania’s oil and gas industry (including both unconventional and conventional wells) produced over 2.9 billion gallons (11 billion litres) of liquid waste, and 1.4 million tons of solid waste.  The concern in the Pennsylvania case is that much of the waste is transported out of the state, the impacts are then spread far and wide.

·      The fate of New York State’s landfill leachate that originates from fracking waste is a core concern, since landfill waste is not inert. If drilling waste contains radioactivity, fracking chemicals, and heavy metals that percolate through the landfill, and the resulting leachate is sent to municipal wastewater treatment plants, will traditional water treatment methods remove those wastes? If not, what will be the impact on public and environmental health in the water body that receives the “treated” wastewater? In Pennsylvania, for example, a case is currently under investigation relating to pollution discharges into the Monongahela River near Pittsburgh. “That water was contaminated with diesel fuels, it’s alleged, carcinogens and other pollutants,” said Rich Bower, Fayette County District Attorney.

·      Currently, a controversial expansion of the Hakes Landfill in Painted Post, New York is in the news. Sierra Club and others were concerned about oversight of radium and radon in the landfill’s leachate and air emissions, presumably stemming from years of receiving drill cuttings. The leachate from the landfill is sent to the Bath Wastewater Treatment plant, which is not equipped to remove radioactivity. “Treated” wastewater from the plant is then discharged into the Cohocton River, a tributary of the Chesapeake Bay. In April 2019, these environmental groups filed a law suit against Hakes C&D Landfill and the Town of Campbell, New York, in an effort to block the expansion.  Similar levels of radioactivity in leachate have also been noted in leachate produced at the Chemung County Landfill, according to Gary McCaslin, President of People for a Healthy Environment, Inc.

• We are still generating large amounts of waste annually and most of our landfill sites are fast approaching full capacity.  Of this waste, at least 90% is landfilled or dumped illegally.  Some of the biggest drivers for waste are population growth, urbanisation, a lack of compliance and general behaviour towards managing waste effectively. This means as our population grows and continues to migrate to urban areas, we are going to produce more waste, which will inevitably exacerbate an already dire situation. We are also dealing with a legacy issue, as many of our landfills are not compliant and are not being managed effectively. This in turn pollutes our natural resources and environment. The pandemic also saw a rise in illegal dumping and a general rise in municipal solid waste production – which naturally put the municipal waste management system under a lot of pressure.

Question: how will the fracking waste be managed to avoid overloading, mostly non-compliant municipal and private landfills, polluting the environment and harming people?

6. Seismicity, Noise and Light pollution
   • Fracking is associated with an increase in seismicity, which has potential to crack dam walls, affect aquifer integrity, underground mines, buildings and so much more.
   • Noise from drilling, trucks, flaring, etc will be experienced beyond the limits of the well pads.
   • Lights for security affecting the enjoyment of rural dark skies, nocturnal creatures and pollenation.
7. Social fabric rupture
   • Loss of other businesses and work e.g. in tourism and agriculture due to inappropriate development, usually in a rural community.
   • Migration of job seekers affecting the planning and budgets for services of municipalities, already teetering or collapsed.  We have just commemorated 10 years since the Marikana Massacre.  We need to learn those lessons.
   • Camps for temporary workers (usually men), which leads to an increase in crime, gender-based violence and other social issues.
   • Boom and bust development, leaving everyone (excepting the connected few) poorer than before and the land will never be restored to its previous condition.
8. Transport and storage
   • The number of trucks associated with fracking is a serious concern for land owners and users, as well as surrounding communities, causing traffic jams, generating dust from using dirt roads and destruction of tarred roads for other road users and the municipality’s budget. 
   • The risk posed to pedestrians and other road users from flying trucks is well known to those of us living along the N3 hell highway.
   • Storage of products (oil &/or gas), wastes (liquid, solid) and raw materials (water, sand, etc) around the well pad will result in emissions to air, spillages and leaks from incidents. 
   • Associated infrastructure – pipelines.  Now here is a whole other nest of vipers.  We do not need new oil or gas pipelines.  They are a risk to everyone from construction, through use to decommissioning, removal and restoration (that is bit we always forget to do!).  The risk to biodiversity is immense and known.
9. Monitoring and Enforcement
   • Methane is more harmful than carbon dioxide over 20 years and is leaked from extraction, through storage and transport to the end user.  It is neither clean nor green, as a recent UNEP article explains:

There is an open secret in the oil and gas industry and it is feeding the climate crisis.  Massive methane leaks, known as super-emitter events, have been taking place at oil and gas fields all over the world, from the United States to Turkmenistan. The releases, most of which can be traced to equipment failures, can last for weeks. One outside of a storage facility in Los Angeles in 2015 hemorrhaged almost 100,000 tonnes of methane — a potent greenhouse gas — into the atmosphere over the course of four months. In June, researchers at Spain’s Polytechnic University of Valencia, said they uncovered the latest known super-emitter event at an oil and gas platform in the Gulf of Mexico. The installation discharged 40,000 tonnes of methane during a 17-day spell in December 2021 — equivalent to 3 per cent of Mexico’s annual oil and gas emissions. Researchers said the release may never have been known to the public if not for the fact that it was captured by a European Space Agency satellite.

• As we have come to know all too well, monitoring and enforcement is not good – especially in the extraction sector.  How on earth are we going to monitor fracking underground, let alone undersea?  How will we know how far the laterals extend, how many there are?   

Let alone if there were a whoopsie and what impacts occurred or are latent? 

We will have to rely on the word of the frackers!?!  Well, that will end well… (puns intended).

The report of the Strategic Environmental Assessment for Karoo Shalegas was completed in 2017 and the Summary for Policy Makers is an essential read for all those needing to understand the bigger picture of the impacts from fracking.  It did not deal, however, with the impacts from fracking for coal bed methane gas, which occurs at a shallower depth and coincides with the eastern water factories (wetlands and related aquatic ecosystems on which KZN, Mpumalanga, Free State and Gauteng relies for water every day!) and associated water storage and pumping infrastructure.

Fracking should be banned. Period.  That it can never be made safe is well known and understood.  We have run out of time for investing in harmful and “white elephant” energy sources and infrastructure.  There are better ways to power our lives and livelihoods.

Picture Caption: A Pennsylvanian resident is able to ignite the water coming out of her kitchen faucet because of methane that has seeped into her well. Many homes in rural areas rely on private wells for drinking water. Picture cred: Les Stone / Greenpeace