Gasland

February 10, 2014

Dear Secretary Moniz:

We write to voice our concern with your continued support of natural gas as a “bridge fuel,” most recently expressed to the U.S. Council of Mayors last month, and also to Platts in December in an interview in which you also suggested that the country’s ban on crude oil exports should be revisited. When even a two- degree rise in the planet’s average temperature may be catastrophic in the view of an increasing number of climate scientists, a national energy policy that relies as heavily as yours does on fracked oil and gas is irresponsible. Developing these antiquated energy sources utilizing extreme extraction methods is only driving us more swiftly to the precipice, not just because it perpetuates our dependence on fossil fuels, but because it employs technologies that allow methane, a much more potent greenhouse gas than carbon dioxide, to leak into the atmosphere at detrimental levels.

Your statements to the U.S. Council of Mayors about implementing best practices and characterizing challenges as manageable suggest that you are completely dismissive of what is happening in communities across this country, where millions of Americans have become test subjects in an uncontrolled public health experiment. Your comments to Platts show a similar disregard for scientists’ warnings about methane’s contribution to climate change. In the Platts interview, comparing CO2 and methane, you said, “Methane, we’re talking more the order of a decade so if we can clamp down, measure, clamp down, reduce those methane emissions then a lot of that, in fact, will go away in a one or two decades’ time scale.”

Your comparison of carbon dioxide and methane falls short in several ways:

It ignores methane’s potency. You refer to a two decades’ time scale, but fail to mention that methane is 84 times more potent than carbon dioxide using that time scale, according to the Intergovernmental Panel on Climate Change’s most recent assessment released in September. The EPA has been criticized for framing its discussion of methane’s potency in a 100-year time scale, which, by the way, uses the outdated Global Warming Potential (GWP) of 21. The IPCC’s assessment increased methane’s GWP from 25 to 28 in that time scale. The criticism comes from those who point out that we only have about 20 years to avoid crossing the two-degree mark, making methane’s potency in that shorter time scale the more relevant one.

It makes no mention of climate change feedback. In short, warming leads to further warming. The IPCC reports that when feedback is taken into account, methane’s GWP in the 20-year time scale increases to 86 and to 34 in the 100-year time scale.i

It does not convey any urgency. Nowhere in your comments do you refer to the two- degree increase we must avoid or the handful of years we have left to avoid it.

It suggests that methane eventually goes away. It doesn’t. Natural gas’ cleaner-burning reputation only means that it contributes less carbon dioxide; yet it still contributes about half as much as coal or oil. Methane that leaks during production, transmission and processing makes its way into the atmosphere in its pure, most potent form. After a decade or so, oxidation converts it into carbon dioxide. It’s a fossil fuel trifecta.

It makes no mention of recommended strategies to scale back use of more potent greenhouse gases. In September, the Intergovernmental Panel on Climate Change issued its comprehensive Fifth Assessment Report (AR5). “Even before the new IPCCassessment, we knew that cutting [methane and other short-lived climate pollutants] could cut warming in half and by two-thirds in the vulnerable Arctic for many decades,”stated Durwood Zaelke, President of the Institute for Governance & Sustainable Development. “Now we know that this strategy is even more important than we first thought… Rapid cuts in CO2 emissions are necessary to stabilize long-term temperatures, but in the near-term, aggressive cuts in SLCPs can provide fast benefits for climate, health, and food security benefits, particularly in the critical vulnerable regions that are already suffering some of the worst impacts of climate change.”ii

It does not address the need for ongoing management of today’s wells. Today’s drilling is contributing to the number of wells that will need to monitored and maintained in perpetuity to ensure that methane is not leaking into the aquifer or air. Even in the short term, new drilling near old wells poses a risk of accidents that isn’t close to being managed. In Pennsylvania alone, the Department of Environmental Protection has admitted that it will take 160 years to cap pre-Marcellus wells and does not require drillers to cap old wells before they drill.

In the Platts interview, you cite two studies. One is the University of Texas/EDF study that has been widely discredited for evaluating methane emissions at sites cherry-picked by the industry. The other is the Harvard study that found U.S. methane emissions to be much higher, as much as 1.5 to 1.7 times higher, than previously thought. You correctly explain that the latter study looks at methane emissions during transmission and processing, but you fail to mention that the University of Texas/EDF study is hardly the final word on emissions at the well pad. In fact, using a new state of the art technique for accurately measuring methane leakage, last year’s study by the University of Colorado, NOAA, and the University of California found leakage rates of 6 – 12 percent, alarmingly high rates that erase any climate benefits natural gas offers.iii

Unfortunately, methane does more than contribute to climate change. President Obama opened his climate change address with examples of impacts we’re already seeing, like shrinking snow packs and record droughts. Indeed, climate change is already impacting our water supply. The consumptive use of water in the hydraulic fracturing process is hard to justify under any circumstances, but absolutely impossible to justify after acknowledging that climate-induced shortages are already occurring.

Even worse, the fracking process itself and the resulting waste are contaminating private water supplies, groundwater, streams and rivers. This summer you told reporters at a Christian Science Monitor event, “I still have not seen any evidence of fracking per se contaminating groundwater.” If the mountain of proof of groundwater contamination had not persuaded you then, perhaps you were persuaded when the Inspector General’s report on the EPA investigation in Parker County, Texas was released on Christmas Eve.iv

Just over 30 years ago, the Precautionary Principle was formulated to guide our decision-making about potentially impactful actions. It said that if scientists had not come to consensus on the safety of a proposed action that could have wide-ranging impacts, the action shouldn’t be carried out. Today, the principle has been turned on its head. We now enter into dangerous industrial practices blindly and demand absolute consensus that they’re unsafe before we even consider stopping them. You call for more data in the Platts interview when every reputable new study tells a worsening story about methane. We believe that sufficient evidence already exists to indicate a need for a national moratorium on shale gas development. We have nothing to gain and everything to lose if you and the administration you serve continue blindly down the path you have taken.

Sincerely,
Stop the Frack Attack Advisory Council

Americans Against Fracking Coalition

The Stop the Frack Attack Network is led by an advisory council of people who are directly impacted by drilling and fracking and are fighting for their rights to clean air and water.

Americans Against Fracking is a national coalition comprised of more than 200 organizations dedicated to banning drilling and fracking for oil and natural gas in order to protect our shared vital resources for future generations.

i Room, Joe. “More Bad News For Fracking: IPCC Warns Methane Traps Much More Heat Than We Thought.” Think Progress.October 2, 2013. http://thinkprogress.org/climate/2013/10/02/2708911/fracking-ipcc-methane/

ii “Climate Threat from Short-Lived Climate Pollutants Upgraded by IPCC in 5th Assessment.” Environmental News Network. October 4, 2013. http://www.enn.com/press_releases/4210

iii Karion, A., et al. (2013) Methane emissions estimate from airborne measurements over a western United States natural gas field Geophys. Res. Lett. 40, 4393 -4397, doi:10.1002/grl.50811.

iv “Response to Congressional Inquiry Regarding the EPA’s Emergency Order to the Range Resources Gas Drilling Company.” U.S. Environmental Protection Agency Inspector General Report No. 14-P-0044. December 20, 2013. http://www.epa.gov/oig/reports/2014/20131220-14-P-0044.pdf