A new report by the Battelle Memorial Institute has concluded that more collaboration between the oil and gas industry and the U.S. Environmental Protection Agency (EPA) could enhance EPA's study into the impact of hydraulic fracturing on U.S. drinking water.
The American Petroleum Institute (API) and America's Natural Gas Alliance (ANGA) last year engaged Battelle Memorial Institute, a non-profit science and technology research and development organization, to conduct a review of EPA's study plan into the potential impact of hydraulic fracturing on drinking water.
API and ANGA officials commissioned the report to address concerns over the direction that EPA's study was taking, said Stephanie Meadows, API senior policy advisor, during a conference call with reporters on Tuesday.
Meadows said Battelle's analysis of the plan for EPA's study reinforces many of API's previously stated concerns about the study and raises new concerns.
"It finds deficiencies in the rigor, funding and focus and stakeholder inclusiveness of the plan," said Meadows.
API's Meadows said the group was not calling on EPA to halt the study, but asking the agency to do the study right.
"Given the industry's extensive experience with production of oil and gas from unconventional reservoirs, its unique expertise in the process of hydraulic fracturing and associated technologies, and its wealth of relevant data and information available to inform this effort, it is a weakness of the study plan, and likely its implementation, that significant industry collaboration is missing," said Battelle in the report.
EPA has stated that the study will seek to answer the questions of whether hydraulic fracturing can impact drinking water resources and, if so, what conditions are associated with these potential impacts.
Battelle noted that while the state purposes, goals and definitions are consistent with the request made in fiscal year 2010 by the U.S. House of Representatives Appropriation Conference Committee, the actual scope and design of the study plan do not provide the same consistency.
Instead, the study reaches beyond studying the relationship between hydraulic fracturing and drinking water, encompassing numerous peripheral elements related to oil and gas exploration and production activity, including various upstream and downstream stages of the water lifecycle, site preparation and development, and standard oil and gas production and other industrial activities.
"This broadening of the scope to 'concerns common to all oil and gas activities' was previously cautioned against by the Scientific Advisory Board," said Battelle in the report.
"Given the scientific importance of the study, the effort likely meets the requirements of a 'highly influential scientific assessment', yet it is not designated as such," said Battelle. "Such designation from the outset would have raised the level of rigor, funding, timing and transparency of all stages of the study."
Battelle took issue with study plan's scope, noting that EPA interprets the congressional intent of the study broadly, including many activities commonly associated with oil and gas development. Departing from a study focused on hydraulic fracturing "risks weakening and obscuring the significance of the research findings" and their relevance to the link between hydraulic fracturing and drinking water.
Additional concerns raised by Battelle's analysis include the limited and possibly statistically biased pool from which the sites were drawn. Much of the data being reviewed for EPA's 2012 study report are being derived from secondary sources, including information requests sent in 2010 to nine service providers and in 2011 to nine hydraulic fracturing operators.
"This represents a small data set of hydraulic fracturing activities," said Battelle. "Caution must be taken in generalizing findings."
Battelle noted that there is no direct evidence documented in the study plan or in associated documents that EPA followed its quality policy in framing the study objectives and developing the study design, as was requested by Congress in "preparing the study in accordance with EPA quality assurance principles."
EPA's approach to the study also does not appear consistent with Congress' request to conduct the study through a transparent, peer-reviewed process that will ensure the validity and accuracy of the data, Battelle said.
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