by Grant Maki
This spring, the Ohio Environmental Council (OEC) and 50 fellow environmental and community organizations sent a letter to state legislators urging them to issue a moratorium on horizontal fracturing until its impacts on the environment and public health are thoroughly studied and effective, science-based regulations can be put in place. The U.S. Environmental Protection Agency (EPA) is conducting a study on these impacts—at a minimum we should wait for the study to be completed, then pass regulations based on sound science and then go ahead with drilling.
These efforts led to a bill currently before the General Assembly. However, the state seems ready to embrace the drilling boom first and do its due diligence second. Horizontal fracturing has already commenced at 20 sites around the state and 65 more have received a full go-ahead from the Ohio Department of Natural Resources.
So even while we push for a moratorium, we are working to ensure that the regulations that are put in place today are as strong as possible. These efforts ran on all cylinders last week, as OEC and its allies submitted comments to both the U.S. EPA and the Ohio EPA on their proposed regulations regarding air pollution emissions from natural gas drilling.
U.S. EPA’ s Proposed Air Regulations
The U.S. EPA proposed a very broad set of rules aimed at the entire oil and natural gas sector. Although the proposal involved many issues, our comments focused on just two of them. Our first priority was to defend the proposed requirement that all new natural gas wells be constructed using a method called “reduced emissions completions.” To understand this requirement, you have to know a little bit about shale gas drilling.
Shale gas wells are “drilled” primarily by forcing special fluids into shale rock formations at high pressure, which fractures the shale (hence the term: “hydrofracturing”). After fracturing, operators release the water pressure, causing large amounts of fluid to flow back to the surface. This flowback fluid contains a significant amount of natural gas, in addition to other potential pollutants. Standard gas collection equipment can’t handle the flowback fluid, so it often sits in storage tanks for days while the gas is either vented into the atmosphere or burned off with a flare—either option causes significant air pollution. A “reduced emissions completion” uses separator equipment that can handle the flowback fluid and also capture (and sell) the natural gas that would otherwise be vented or flared.
We defended the U.S. EPA’s proposal to require “reduced emissions completion” against arguments from industry that it was too expensive or unduly burdensome. We also focused on an issue that was flying under the radar: the U.S. EPA’s idea of using industry-funded third parties to do some of the oversight and monitoring. Although we recognize potential benefits if third-party verifiers are truly independent, such a system could lead to serious conflicts of interest. Thus we suggested ways for the U.S. EPA to minimize conflicts of interest.
Ohio EPA’s Air Pollution General Permit
At the same time that the federal regulations were coming down the pipe, the Ohio EPA sought public comments on a proposed general permit that will allow companies to start drilling whenever they meet certain qualifying criteria and agree to abide by certain emissions and operational standards.
Given that the state has decided to go ahead with drilling before learning from the mistakes of other states, we are pleased to see that the Ohio EPA is at least showing willingness to start regulating using the knowledge we have. Unfortunately, the Ohio EPA’s proposed general permit had a number of holes in it that could mean a lot of pollution in Eastern Ohio. OEC, the Buckeye Forest Council, the Center for Health Environment & Justice, and the Group Against Smog and Pollution (GASP) submitted two rounds of comments to the Ohio EPA, addressing a number of issues. GASP’s expertise and experience with the same issues in Western Pennsylvania we hope will educate the Ohio EPA to learn from hiccups to our east, and fix the deficiencies with the proposed permit.
Revisions are Necessary for the Final General Permit
The draft general permit puts no requirements on well completions. We urged the Ohio EPA to require reduced emissions completions. The U.S. EPA has come under fire from industry for their proposal to require reduced emissions completions, and the requirement might be struck from the final federal rule. The Ohio EPA should play it safe and enact the same requirement, especially in a general permit that specifies conditions where a drilling proposal can be approved with no stakeholder input and no further scrutiny from the Ohio EPA.
For another thing, the draft general permit is silent on produced water storage tanks. “Produced water” is a saline fluid that occurs naturally in the shale formations and flows to the surface during fracking. Produced water storage tanks produce emissions that can’t be overlooked, as states like Colorado and Wyoming have recognized.
Another issue we had is that the general permit would allow significant drilling operations to commence without stakeholder input. We pushed the agency to give the public an opportunity to be heard when industry proposes large-scale drilling operations, and for proposals to drill near “urbanized areas” which is defined as a town of more than 5,000 in Ohio Administrative Code 1501:9-1-01(A).
Among other comments, we also pushed the agency to require drillers to notify them before undertaking any action that would produce significant emissions, in order to help the agency develop better information about the fracking industry.
Click on the links to read OEC’s comments to the Ohio EPA on its general permit, GASP’s comments on the general permit and comments to the U.S. EPA’s Air Proposed Regulations
The numbers listed above are current as of Nov. 28, 2011. Lists of Utica and Marcellus shale permits are available at http://www.ohiodnr.com/portals/11/oil/pdf/Utica.pdf and http://www.ohiodnr.com/portals/11/oil/pdf/Marcellus.pdf.
For more information and updates, click here.
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By Daisy Simmons
1. Stay Informed<p>A first order of business in pet evacuation planning is to understand and be ready for the possible threats in your area. Visit <a href="https://www.ready.gov/be-informed" target="_blank">Ready.gov</a> to learn more about preparing for potential disasters such as floods, hurricanes, and wildfires. Then pay attention to related updates by tuning <a href="http://www.weather.gov/nwr/" target="_blank">NOAA Weather Radio</a> to your local emergency station or using the <a href="https://www.fema.gov/mobile-app" target="_blank">FEMA app</a> to get National Weather Service alerts.</p>
2. Ensure Your Pet is Easily Identifiable<p><span>Household pets, including indoor cats, should wear collars with ID tags that have your mobile phone number. </span><a href="https://www.avma.org/microchipping-animals-faq" target="_blank" rel="noopener noreferrer">Microchipping</a><span> your pets will also improve your chances of reunion should you become separated. Be sure to add an emergency contact for friends or relatives outside your immediate area.</span></p><p>Additionally, use <a href="https://secure.aspca.org/take-action/order-your-pet-safety-pack" target="_blank" rel="noopener noreferrer">'animals inside' door/window stickers</a> to show rescue workers how many pets live there. (If you evacuate with your pets, quickly write "Evacuated" on the sticker so first responders don't waste time searching for them.)</p>
3. Make a Pet Evacuation Plan<p> "No family disaster plan is complete without including your pets and all of your animals," says veterinarian Heather Case in <a href="https://www.youtube.com/watch?v=Q9NRJkFKAm4" target="_blank">a video</a> produced by the American Veterinary Medical Association.</p><p>It's important to determine where to take your pet in the event of an emergency.</p><p>Red Cross shelters and many other emergency shelters allow only service animals. Ask your vet, local animal shelters, and emergency management officials for information on local and regional animal sheltering options.</p><p>For those with access to the rare shelter that allows pets, CDC offers <a href="https://www.cdc.gov/healthypets/emergencies/pets-in-evacuation-centers.html" target="_blank">tips on what to expect</a> there, including potential health risks and hygiene best practices.</p><p>Beyond that, talk with family or friends outside the evacuation area about potentially hosting you and/or your pet if you're comfortable doing so. Search for pet-friendly hotel or boarding options along key evacuation routes.</p><p>If you have exotic pets or a mix of large and small animals, you may need to identify multiple locations to shelter them.</p><p>For other household pets like hamsters, snakes, and fish, the SPCA recommends that if they normally live in a cage, they should be transported in that cage. If the enclosure is too big to transport, however, transfer them to a smaller container temporarily. (More on that <a href="https://www.spcai.org/take-action/emergency-preparedness/evacuation-how-to-be-pet-prepared" target="_blank" rel="noopener noreferrer">here</a>.)</p><p>For any pet, a key step is to establish who in your household will be the point person for gathering up pets and bringing their supplies. Keep in mind that you may not be home when disaster strikes, so come up with a Plan B. For example, you might form a buddy system with neighbors with pets, or coordinate with a trusted pet sitter.</p>
4. Prepare a Pet Evacuation Kit<p>Like the emergency preparedness kit you'd prepare for humans, assemble basic survival items for your pets in a sturdy, easy-to-grab container. Items should include:</p><ul><li>Water, food, and medicine to last a week or two;</li><li>Water, food bowls, and a can opener if packing wet food;</li><li>Litter supplies for cats (a shoebox lined with a plastic bag and litter may work);</li><li>Leashes, harnesses, or vehicle restraints if applicable;</li><li>A <a href="https://www.avma.org/resources/pet-owners/emergencycare/pet-first-aid-supplies-checklist" target="_blank">pet first aid kit</a>;</li><li>A sturdy carrier or crate for each cat or dog. In addition to easing transport, these may serve as your pet's most familiar or safe space in an unfamiliar environment;</li><li>A favorite toy and/or blanket;</li><li>If your pet is prone to anxiety or stress, the American Kennel Club suggests adding <a href="https://www.akc.org/expert-advice/home-living/create-emergency-evacuation-plan-dog/" target="_blank" rel="noopener noreferrer">stress-relieving items</a> like an anxiety vest or calming sprays.</li></ul><p>In the not-unlikely event that you and your pet have to shelter in different places, your kit should also include:</p><ul><li>Detailed information including contact information for you, your vet, and other emergency contacts;</li><li>A list with phone numbers and addresses of potential destinations, including pet-friendly hotels and emergency boarding facilities near your planned evacuation routes, plus friends or relatives in other areas who might be willing to host you or your pet;</li><li>Medical information including vaccine records and a current rabies vaccination tag;</li><li>Feeding notes including portions and sizes in case you need to leave your pet in someone else's care;</li><li>A photo of you and your pet for identification purposes.</li></ul>
5. Be Ready to Evacuate at Any Time<p>It's always wise to be prepared, but stay especially vigilant in high-risk periods during fire or hurricane season. Practice evacuating at different times of day. Make sure your grab-and-go kit is up to date and in a convenient location, and keep leashes and carriers by the exit door. You might even stow a thick pillowcase under your bed for middle-of-the-night, dash-out emergencies when you don't have time to coax an anxious pet into a carrier. If forecasters warn of potential wildfire, a hurricane, or other dangerous conditions, bring outdoor pets inside so you can keep a close eye on them.</p><p>As with any emergency, the key is to be prepared. As the American Kennel Club points out, "If you panic, it will agitate your dog. Therefore, <a href="https://www.akc.org/expert-advice/home-living/create-emergency-evacuation-plan-dog/" target="_blank" rel="noopener noreferrer">pet disaster preparedness</a> will not only reduce your anxiety but will help reduce your pet's anxiety too."</p>
Evacuating Horses and Other Farm Animals<p>The same basic principles apply for evacuating horses and most other livestock. Provide each with some form of identification. Ensure that adequate food, water, and medicine are available. And develop a clear plan on where to go and how to get there.</p><p>Sheltering and transporting farm animals requires careful coordination, from identifying potential shelter space at fairgrounds, racetracks, or pastures, to ensuring enough space is available in vehicles and trailers – not to mention handlers and drivers on hand to support the effort.</p><p>For most farm animals, the Red Cross advises that you consider precautionary evacuation when a threat seems imminent but evacuation orders haven't yet been announced. The American Veterinary Medical Association has <a href="https://www.avma.org/resources/pet-owners/emergencycare/large-animals-and-livestock-disasters" target="_blank">more information</a>.</p>
Bottom Line: If You Need to Evacuate, So Do Your Pets<p>As the Humane Society warns, pets left behind in a disaster can easily be injured, lost, or killed. Plan ahead to make sure you can safely evacuate your entire household – furry members included.</p>
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