My Comment to TAB on DEP’s Search for Data to Support Road Spreading of Brine

Here is the comment I made to the DEP’s Technical Advisory Board at its September 9 meeting.

My name is Karen Feridun, Founder of Berks Gas Truth and Co-founder of the Better Path Coalition. Thank you for the opportunity to comment.

I’ll be interested to hear Mr. Perry’s comments on the PennState study on road spreading of drilling waste.

We are at a place in human history when every penny of DEP’s budget and every ounce of their effort should be put toward saving the planet from the climate crisis, not enabling the industry that caused it and is killing us.

And so it is extremely concerning that Mr. Klapkowski made unambiguous comments at the August 19 meeting of the PA Grade Crude Development Advisory Council that indicate that DEP is looking for data to support a road spreading program that will survive the court challenges establishing it will create.

He said, “We have to be able to defend our decisions with data. And that was the attempt, with working with Penn State, that’s what we were attempting to do was to develop that data to be able to have a program that we could go to the Environmental Hearing Board and the Commonwealth Court and Supreme Court under the constitution and under the statutes that we administer, that would be defensible.”

The fact is, we don’t need another study. There is ample evidence that road spreading of drilling waste is dangerous to the environment and human health. Nevertheless, more research is never a bad thing when it helps us deepen our understanding, but this ain’t that. Shopping for data to support a decision DEP has already made is something else entirely.

But the ongoing distinction between conventional and unconventional drilling is an artificial one in the first place. This is from PIOGA’s website. “A traditional, conventional well is usually drilled into a sandstone formation that can range from as shallow as 1,500 feet to as much as 21,000 feet deep. Oil and gas are able to pass through these formations without hydraulic fracturing, but nearly all wells are stimulated through fracturing to improve production.”

There is a ban on road spreading of fracking waste. That ban should apply to the spreading of conventional waste, not just unconventional waste. And, incidentally, extending the ban would close the preposterous loophole of coproduct self-determination that makes the current moratorium pointless anyway.

Thank you.