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CONSERVATION GROUPS’ COMMENTS
<br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS
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<br />thorough analysis to be performed by the UFO, which the agency failed to provide in the RMP
<br />and EIS.
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<br />The dangers and impacts of fracking can be found at every stage of the oil and gas
<br />production process. For example, fracking’s waste stream can result in dramatic impacts –
<br />requiring onsite waste injection, trucking used frack fluids (“flowback”) offsite, and in some
<br />cases even the direct release of fracking waste into watercourses – the impacts of which can be
<br />compounded by ineffective or nonexistent regulation.304 As detailed herein, natural gas
<br />production itself can be inefficient and wasteful – with practices such as the venting of
<br />methane, 305 and the use of vast quantities of water in the fracking process.306 In addition to being
<br />wasteful, these practices can also be quite harmful to human health and the environment.
<br />1. Impacts from Hydraulic Fracturing Are Well Documented.
<br />
<br />The potential impacts that may result from hydraulic fracturing are myriad and
<br />significant; and include, among others, impacts to water quality and supply, impacts to habitat
<br />and wildlife, impacts to human health, as well as impacts on greenhouse gas emissions and air
<br />quality.307 Although industry often asserts that hydraulic fracturing is safe and doesn’t result in
<br />contamination or harm to people and the environment, the New York Times recently uncovered
<br />a 1987 U.S. Environmental Protection Agency (“EPA”) report to Congress which found, among
<br />other things, that fracking can cause groundwater contamination, and cites as an example a case
<br />where hydraulic fracturing fluids contaminated a water well in West Virginia.308 The EPA
<br /> 304 See Abrahm Lustgarten, The Trillion Gallon Loophole: Lax Rules for Drillers that Inject
<br />Pollutants Into the Earth, PROPUBLICA, Sept. 20, 2012, available at:
<br />https://www.propublica.org/article/trillion-gallon-loophole-lax-rules-for-drillers-that-inject-
<br />pollutants/single#republish (attached as Exhibit 162); Earthworks, Breaking All the Rules: The
<br />Crisis in Oil & Gas Regulatory Enforcement, September 2012 (attached as Exhibit 163). 305 Energy Policy Research Foundation, Lighting up the Prairie: Economic Considerations in
<br />Natural Gas Flaring, Sept. 5, 2012 (attached as Exhibit 164); see also, James Hansen, et. al.,
<br />Greenhouse gas growth rates, PNAS, vol. 101, no. 46, 16109-16114, Sept. 29, 2004 (attached as
<br />Exhibit 165) (curtailing methane waste is seen as a “vital contribution toward averting dangerous
<br />anthropogenic interference with global climate.”). 306 See GAO, Energy-Water Nexus: Coordinated Federal Approach Needed to Better Manage
<br />Energy and Water Tradeoffs (Sept. 2012) (attached as Exhibit 166); Nicholas Kusnetz, The
<br />Bakken oil play spurs booming business – in water, High Country News, Sept. 5, 2012, available
<br />at: http://www.hcn.org/issues/44.13/the-bakken-oil-play-spurs-a-booming-business-in-
<br />water/print_view (attached as Exhibit 167). 307 See, e.g., National Wildlife Federation, No More Drilling in the Dark: Exposing the Hazards
<br />of Natural Gas Production and Protecting America’s Drinking Water and Wildlife Habitats
<br />(2011), available at: http://www.nwf.org/News-and-Magazines/Media-
<br />Center/Reports/Archive/2011/No-More-Drilling-in-the-Dark.aspx (attached as Exhibit167); see
<br />also United States Forest Service, Chloride Concentration Gradients in Tank-Stored Hydraulic
<br />Fracturing Fluids Following Flowback (Nov. 2010), available at: http://nrs.fs.fed.us/pubs/38533/
<br />(last visited Oct. 27, 2016) (attached as Exhibit 168). 308 See U.S. Environmental Protection Agency, Report to Congress, Management of Wastes from
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