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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />109 <br /> <br />Oil and gas development is one of the largest sources of VOCs, ozone, and sulfur dioxide <br />emissions in the United States. Nevertheless, the agency’s preferred Alternative D leaves <br />available approximately 865,970 surface acres within the planning area for oil and gas leasing <br />and development, accounting for the development of approximately 330 federal wells. DEIS at <br />2-10, 4-36. The relationship between air quality and human health must be analyzed in the <br />RMP/EIS. The failure of the UFO to do so, here, represents a fundamental shortcoming of the <br />agency’s analysis, and must be corrected. “The agency must examine the relevant data and <br />articulate a satisfactory explanation for its action including a ‘rational connection between the <br />facts found and the choice made.’” Motor Vehicle Mfrs., 463 U.S. at 43 (1983). <br />B. The UFO Has Failed to Take a “Hard Look” at Resource Impacts from <br />Hydraulic Fracturing. <br /> <br />Although advances in oil and gas extraction techniques – namely hydraulic fracturing, or <br />“fracking” – have undoubtedly resulted in a growth of domestic production, the wisdom of these <br />advances with regard to other resource values and human health is still very much in question.301 <br />As described in detail below, there is a wealth of information and reports stressing the dangers of <br />fracking that must be considered in the agency’s subject NEPA analysis. Of course, given the <br />national attention and debate that fracking is generating, significant sources of new information <br />and research are being consistently published warning against the dangers and impacts that <br />fracking can produce, which must also be considered by the agency. <br /> <br />For example, as discussed in more detail below, hydraulic fracturing was identified as <br />one of several causes of methane contamination of drinking water and a subsequent explosion at <br />a home in Bainbridge Township, Ohio. Spills of hydraulic fracturing fluid into the Acorn Fork <br />Creek in Kentucky resulted in a fish kill that affected the threatened Blackside Dace among other <br />species. Also, one study modeled that chemically concentrated fracking fluids can migrate into <br />groundwater aquifers within a matter of years – calling into question industry claims that rock <br />layers separating aquifers are impervious to these pollutants.302 Claims that there has never been <br />a documented case of groundwater contamination from fracking was challenged by EPA’s <br />research in Pavillion, Wyoming. Indeed, a second round of testing in the Pavillion area was <br />recently performed by the U.S. Geological Survey, which supported EPA’s preliminary findings <br />that hydraulic fracturing resulted in groundwater contamination.303 Even in draft form, the <br />Pavillion Report and its troubling findings as well as incidents described above and other <br />evidence of fracking related contamination from around the country underscore the need for <br /> 301 See, e.g., A.R. Ingraffea, et. al., Natural Gas, Hydraulic Fracking and a Bridge to Where? <br />(April 2011) (attached as Exhibit 158). 302 See, Abrahm Lustgarten, New Study Predicts Frack Fluids can Migrate to Aquifers Within <br />Years, PROPUBLICA, May 1, 2012, available at: https://www.propublica.org/article/new-study- <br />predicts-frack-fluids-can-migrate-to-aquifers-within-years (attached as Exhibit 159); Josh Fox, <br />The Sky is Pink: Annotated Documents (attached as Exhibit 160). 303 Peter Wright, et. al., U.S. Geological Survey, Groundwater-Quality and Quality-Control Data <br />for Two Monitoring Wells near Pavillion, Wyoming, April and May 2012 (attached as Exhibit <br />161).