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Mr. Fred Krupp, President
Environmental Defense Fund
257 Park Avenue South
New York, NY 10010
Dear Mr. Krupp:
Those of us concerned with charting a rational and sustainable energy policy for the
United States were disheartened to see the Environmental Defense Fund (EDF) lend its
name and support to an entity called the Center for Sustainable Shale Development
(CSSD). The very use of the word sustainable in the name is misleading, because there is
nothing sustainable about shale oil or shale gas.
These are fossil fuels, and their extraction and consumption will inevitably degrade our
environment and contribute to climate change. Hydraulic fracturing, the method used to
extract them, will permanently remove huge quantities of water from the hydrological
cycle, pollute the air, contaminate drinking water, and release high levels of methane into
the atmosphere. It should be eminently clear to everyone that an economy based on fossil
fuels is unsustainable.
CSSD bills itself as a collaborative effort between “diverse interests with a common
goal,” but our goals as a nation are not, and cannot, be the same as those of Chevron,
CONSOL Energy, EQT Corporation, and Shell, all partners in CSSD. These corporations
are interested in extracting as much shale gas and oil as possible, and at a low cost. We
are interested in minimizing the extraction and consumption of fossil fuels and in
facilitating a rapid transition to the real sustainable energy sources—the sun, the wind,
and hydropower.
As you know, Jacobson et al. recently published a study showing that New York State
could derive all its energy from renewable sources by the year 2030 using existing
technologies. Clearly this model, which can be replicated in Pennsylvania and other parts
of the country, calls into question the whole notion of expanding shale oil and gas
extraction.
That said, we do recognize the need to limit the damage and destruction caused by
ongoing extraction operations, but we do not believe that voluntary standards, approved
by the industry and “greenwashed” by an environmental organization are the way to go
about it. There is a better way to protect the public—it’s called regulation. The oil and
gas industry is exempt from scores of state and federal laws and regulations, including
key provisions of the Clean Air Act, Clean Water Act, Safe Drinking Water Act, and
Comprehensive Environmental Response, Compensation, and Liability Act. Any genuine
effort to limit the damage caused by oil and gas extraction begins by closing these legal
and regulatory loopholes, but as far as we can tell, CSSD does not advocate this
important, commonsense measure. Responsible oil and gas corporations should welcome
strict regulations and enforcement with damage-proportional fines, because they will
apply to the bad actors as well as good corporate citizens.
It is disappointing that the voluntary performance standards set by CSSD often fall far
short of what are widely acknowledged to be best management practices. For example,
Performance Standard No. 4 calls for open, double-lined pits to store flowback fluid,
although closed-loop drilling systems and tank storage do a much better job of
minimizing air, soil and water contamination and protecting wildlife—which, not
incidentally, also enters the human food chain.
From a public health perspective, there are other glaring faults with the CSSD
performance standards. Performance Standard No. 7 permits operators to limit disclosure
of the chemicals they inject underground by citing trade secret protection. We simply do
not believe commercial interests can be allowed to trump public health concerns
regarding underground injection.
The lax nature of these standards is no doubt due in part to the fact that the partners in
CSSD apparently failed to consult with the local communities that are impacted by shale
extraction operations. It is doubtful that the tens of millions of Americans who live “on
the shale” would approve of open waste pits or the underground injection of undisclosed
toxic chemicals in the vicinity of their water wells.
While EDF is free to partner with the gas industry in CSSD, we feel it is important that
the press and the public clearly understand that neither EDF nor CSSD represents the
environmental and public health communities on the subject of shale oil and gas
extraction.
Sincerely,
Civil Society Institute
Earthworks
Jennifer Krill, Executive Director
Friends of the Earth (US)
Greenpeace
Phil Radford
Executive Director
Josh Fox
Dominic Frongillo
Councilmember and Deputy Town Supervisor
Town of Caroline, New York
A.R. Ingraffea, Ph.D., P.E.
Dwight C. Baum Professor of Engineering
Cornell University
Robert W. Howarth, Ph.D.
David R. Atkinson Professor of Ecology and Environmental Biology
Founding Editor, Biogeochemistry
Cornell University
Robert Kennedy, Jr.
Mark Ruffalo
Debra Winger
Advocates for Morris
Morris, NY
Maureen Dill
Appalachian Citizens’ Law Center
Whitesburg, KY
Stephen A. Saunders
Athens County (OH) Fracking Action Network
Heather Cantino
Bashakill Area Association
Wurtsboro, NY
Berks Gas Truth
Kutztown, PA
Karen Feridun, Founder
Beyond Nuclear
Takoma Park, MD
Kevin Kamps
Catskill Citizens for Safe Energy
Bruce Ferguson
Fremont Center, NY
Coalition for a Frack-Free Tennessee
Eric Lewis
Concerned Citizens of Otsego, New York
Stuart Anderson
Cumberland Center for Justice and Peace
Leslie Lytle, Executive Director
Citizen’s Action Coalition (Indiana)
Kerwin Olson, Executive Director
Citizens’ Environmental Coalition
Albany, NY
Barbara Warren
Chesapeake Climate Action Network
Mike Tidwell, Executive Director
Coal River Mountain Watch
Vernon Halton, Executive Director
Christians for the Mountains
Allen Johnson
Citizens’ Greener Evanston
Evanston, IL
Coalition for a Nuclear Free Great Lakes
Concerned Citizens of Darby (New York)
Gay Garrison, Co-Chair
Citizens for a Healthy Community
Paonia, Colorado
Delaware Riverkeeper Network
Maya K. van Rossum, the Delaware Riverkeeper
Damascus Citizens for Sustainability
B. Arrindell, Director
The Edge
Suzanne Moynahan
Fleased
Slaterville Springs, NY
Ellen Z. Harrison, Executive Director
Gas Drilling Awareness Coalition of Luzerne County (PA)
Alfonso Rodriguez, M.D.
Healing Ourselves and Mother Earth
Jennifer Olaranna Viereck, Executive Director
Interfaith Care Network
Sally Wingate
Institute for Policy Studies Sustainable Energy and Economy Network
Janet Redman
Labor Network for Sustainability
Joe Uehlein
Lehigh Valley Gas Truth
Julie Edgar, Organizer
Los Alamos Study Group
Albuquerque, NM
Luzerne County Citizens for Clean Air
Nancy Dolan
Missourians for Safe Energy
Mark Haim, Chair
Mountain Justice
West Virginia
New York 4 Whales
North Carolina WARN
Jim Warren, Executive Director
Northern Plains Resource Council
Walter Archer, Chair
Ohio Valley Environmental Coalition
Janet Keating, Executive DIrector
Otsego 2000
Ellen Pope, Executive Director
Otsego Neighbors
Julie Huntsman, DVM; Councilwoman, Town of Otsego
Pennsylvania Alliance for Clean Water and Air
Jenny Lisak, Co-Director
Pepacton Institute LLC
Jannette M. Barth Ph.D.
Public Citizen’s Energy Program
Allison Fisher
Responsible Drilling Alliance
Williamsport, PA
Renewable Energy Long Island
Gordian Raacke, Executive Director
Sanford-Oquaga Area Concerned Citizens (S-OACC)
Sullivan Area Citizens for Responsible Energy Development (SACRED)
Karen London, Esq., Co-Founder
Sierra Club Long Island Group
Ann Aurelio
Statewide Organizing for Community eMpowerment (SOCM)
Knoxville, Tennessee
Shaleshock Alliance
Lisa Wright
San Juan Citizens Alliance (Durango, CO)
Dan Randolph
Sustainable Tompkins
Tom Shelley, Chair
Tour de frack
Evans City, PA
Jason Bell
United for Action
David Braun
Westchester for Change
Susan Van Dolsen, Co-Organizer
WESPAC Foundation
Nada Khader, Executive Director
Women’s Energy Matters
Barbara George, President

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Letter from Eco-Groups Shunning the Environmental Defense Fund

  • 1. Mr. Fred Krupp, President Environmental Defense Fund 257 Park Avenue South New York, NY 10010 Dear Mr. Krupp: Those of us concerned with charting a rational and sustainable energy policy for the United States were disheartened to see the Environmental Defense Fund (EDF) lend its name and support to an entity called the Center for Sustainable Shale Development (CSSD). The very use of the word sustainable in the name is misleading, because there is nothing sustainable about shale oil or shale gas. These are fossil fuels, and their extraction and consumption will inevitably degrade our environment and contribute to climate change. Hydraulic fracturing, the method used to extract them, will permanently remove huge quantities of water from the hydrological cycle, pollute the air, contaminate drinking water, and release high levels of methane into the atmosphere. It should be eminently clear to everyone that an economy based on fossil fuels is unsustainable. CSSD bills itself as a collaborative effort between “diverse interests with a common goal,” but our goals as a nation are not, and cannot, be the same as those of Chevron, CONSOL Energy, EQT Corporation, and Shell, all partners in CSSD. These corporations are interested in extracting as much shale gas and oil as possible, and at a low cost. We are interested in minimizing the extraction and consumption of fossil fuels and in facilitating a rapid transition to the real sustainable energy sources—the sun, the wind, and hydropower. As you know, Jacobson et al. recently published a study showing that New York State could derive all its energy from renewable sources by the year 2030 using existing technologies. Clearly this model, which can be replicated in Pennsylvania and other parts of the country, calls into question the whole notion of expanding shale oil and gas extraction. That said, we do recognize the need to limit the damage and destruction caused by ongoing extraction operations, but we do not believe that voluntary standards, approved by the industry and “greenwashed” by an environmental organization are the way to go about it. There is a better way to protect the public—it’s called regulation. The oil and gas industry is exempt from scores of state and federal laws and regulations, including
  • 2. key provisions of the Clean Air Act, Clean Water Act, Safe Drinking Water Act, and Comprehensive Environmental Response, Compensation, and Liability Act. Any genuine effort to limit the damage caused by oil and gas extraction begins by closing these legal and regulatory loopholes, but as far as we can tell, CSSD does not advocate this important, commonsense measure. Responsible oil and gas corporations should welcome strict regulations and enforcement with damage-proportional fines, because they will apply to the bad actors as well as good corporate citizens. It is disappointing that the voluntary performance standards set by CSSD often fall far short of what are widely acknowledged to be best management practices. For example, Performance Standard No. 4 calls for open, double-lined pits to store flowback fluid, although closed-loop drilling systems and tank storage do a much better job of minimizing air, soil and water contamination and protecting wildlife—which, not incidentally, also enters the human food chain. From a public health perspective, there are other glaring faults with the CSSD performance standards. Performance Standard No. 7 permits operators to limit disclosure of the chemicals they inject underground by citing trade secret protection. We simply do not believe commercial interests can be allowed to trump public health concerns regarding underground injection. The lax nature of these standards is no doubt due in part to the fact that the partners in CSSD apparently failed to consult with the local communities that are impacted by shale extraction operations. It is doubtful that the tens of millions of Americans who live “on the shale” would approve of open waste pits or the underground injection of undisclosed toxic chemicals in the vicinity of their water wells. While EDF is free to partner with the gas industry in CSSD, we feel it is important that the press and the public clearly understand that neither EDF nor CSSD represents the environmental and public health communities on the subject of shale oil and gas extraction. Sincerely, Civil Society Institute Earthworks Jennifer Krill, Executive Director Friends of the Earth (US) Greenpeace Phil Radford Executive Director Josh Fox
  • 3. Dominic Frongillo Councilmember and Deputy Town Supervisor Town of Caroline, New York A.R. Ingraffea, Ph.D., P.E. Dwight C. Baum Professor of Engineering Cornell University Robert W. Howarth, Ph.D. David R. Atkinson Professor of Ecology and Environmental Biology Founding Editor, Biogeochemistry Cornell University Robert Kennedy, Jr. Mark Ruffalo Debra Winger Advocates for Morris Morris, NY Maureen Dill Appalachian Citizens’ Law Center Whitesburg, KY Stephen A. Saunders Athens County (OH) Fracking Action Network Heather Cantino Bashakill Area Association Wurtsboro, NY Berks Gas Truth Kutztown, PA Karen Feridun, Founder Beyond Nuclear Takoma Park, MD Kevin Kamps Catskill Citizens for Safe Energy Bruce Ferguson Fremont Center, NY
  • 4. Coalition for a Frack-Free Tennessee Eric Lewis Concerned Citizens of Otsego, New York Stuart Anderson Cumberland Center for Justice and Peace Leslie Lytle, Executive Director Citizen’s Action Coalition (Indiana) Kerwin Olson, Executive Director Citizens’ Environmental Coalition Albany, NY Barbara Warren Chesapeake Climate Action Network Mike Tidwell, Executive Director Coal River Mountain Watch Vernon Halton, Executive Director Christians for the Mountains Allen Johnson Citizens’ Greener Evanston Evanston, IL Coalition for a Nuclear Free Great Lakes Concerned Citizens of Darby (New York) Gay Garrison, Co-Chair Citizens for a Healthy Community Paonia, Colorado Delaware Riverkeeper Network Maya K. van Rossum, the Delaware Riverkeeper Damascus Citizens for Sustainability B. Arrindell, Director The Edge Suzanne Moynahan
  • 5. Fleased Slaterville Springs, NY Ellen Z. Harrison, Executive Director Gas Drilling Awareness Coalition of Luzerne County (PA) Alfonso Rodriguez, M.D. Healing Ourselves and Mother Earth Jennifer Olaranna Viereck, Executive Director Interfaith Care Network Sally Wingate Institute for Policy Studies Sustainable Energy and Economy Network Janet Redman Labor Network for Sustainability Joe Uehlein Lehigh Valley Gas Truth Julie Edgar, Organizer Los Alamos Study Group Albuquerque, NM Luzerne County Citizens for Clean Air Nancy Dolan Missourians for Safe Energy Mark Haim, Chair Mountain Justice West Virginia New York 4 Whales North Carolina WARN Jim Warren, Executive Director Northern Plains Resource Council Walter Archer, Chair Ohio Valley Environmental Coalition Janet Keating, Executive DIrector
  • 6. Otsego 2000 Ellen Pope, Executive Director Otsego Neighbors Julie Huntsman, DVM; Councilwoman, Town of Otsego Pennsylvania Alliance for Clean Water and Air Jenny Lisak, Co-Director Pepacton Institute LLC Jannette M. Barth Ph.D. Public Citizen’s Energy Program Allison Fisher Responsible Drilling Alliance Williamsport, PA Renewable Energy Long Island Gordian Raacke, Executive Director Sanford-Oquaga Area Concerned Citizens (S-OACC) Sullivan Area Citizens for Responsible Energy Development (SACRED) Karen London, Esq., Co-Founder Sierra Club Long Island Group Ann Aurelio Statewide Organizing for Community eMpowerment (SOCM) Knoxville, Tennessee Shaleshock Alliance Lisa Wright San Juan Citizens Alliance (Durango, CO) Dan Randolph Sustainable Tompkins Tom Shelley, Chair Tour de frack Evans City, PA Jason Bell
  • 7. United for Action David Braun Westchester for Change Susan Van Dolsen, Co-Organizer WESPAC Foundation Nada Khader, Executive Director Women’s Energy Matters Barbara George, President