Good morning,

My name is Jason Bell. I’m a resident of Evans City and a Soergels’ regular. Earlier this week I met

several local residents who have been experiencing water problems in the Connoquenessing Township

area. The EPA and REX Energy (the company who is preforming shale drilling the area) have both

tested the water of at least two homes and have found elevated levels of many man-made chemicals in

the well water. The water is black and purple, stains the bathtubs and dishes, and foams out of the

faucet.

One woman’s family was violently ill with vomiting and uncontrollable diarrhea for weeks before their

water turned foamy. Her fingernails have changed pigmentation (called leukonychia) and her personal

physician believes that she has arsenic poisoning. She has been sent for further testing.

Another blind and elderly woman has been left without any water.

A third is being forced to move because here water and soil has been irreparably contaminated. She has

the water tests to prove it.

It s truly a sad situation and all of them blame the sudden changes on the new drilling taking place in

their backyards. There have never been any water problems of this nature in the area and within months

of the start of drilling near their property, these problems began.

Yesterday I was told that the land where the drilling is taking place is associated with Soergels Is this

true and if so have you been made aware of what is happening in Connoquenessing Township? Is there

produce in your market that is grown on this land or any others where fracking fluids are used or

stored? If so do you use well water for watering? Is the water tested?

I look forward to your responses and I hope that you can understand that until my concerns are eased I

will not be shopping at Soergels.

Jason Bell

223 Pattison St.

Evans City, PA 16033

Email from Soergel Orchards

From: Soergel Orchards <folks@soergels.com>

To: ‘Jason Bell’ <trucodiosyahoo.com>

Sent: Monday, September 26, 2011 9:26 AMSubject: RE: Connoquenessing Township

Hi Jason,

Thank you for the e-mail, and thank you for the support of our family’s business. As for the e

mail and information contained in it, I can tell you that we do have land that is leased to REX

Energy, and I do know that water tests from our property have come back unchanged. Beyond
Eric Voll

General ManagerSoergel Orchards

6th Generation

724-935-1743

Northeastern Pennsylvania Marcellus Shale Short-Term Ambient Air Sampling Report

The scope of this short-term sampling effort was limited to several natural gas facilities in

Susquehanna County. Due to the limited scope and duration of the sampling and the limited

number of sources and facilities sampled, the findings only represent conditions at the time of

the sampling and do not represent a comprehensive study of emissions. While this short-term

sampling effort does not address the cumulative impact of air emissions from natural gasoperations in northeastern Pennsylvania, the sampling results do provide basic information on

the type of pollutants emitted to the atmosphere during selected phases of gas extraction

operations in the Marcellus Shale formation. This information will also be utilized to determine if

the scope of the study should be expanded and will identify areas where additional sampling

may be warranted.
moving into my area. I had concerns but they were mostly about

traffic and taxation.

I sat down to write a letter to my state representative and starting

doing some research to see if my worries had any merit. What I

found eventually led me 4 miles from my home, to

Connoquenessing Township

The short video I’m about to show you focuses on Kim McElroy

and her three-year-old daughter, Skylar. I hope you find it

informative.

Video:

What she says about the headaches is true. Mine started when

the center of my forehead, right here, started to heat up. In a

short time it was all over my head. I could smell nothing, but my

eyes were watering and I could taste metal in my mouth and on

my lips. A home owner explained to me that the wind was blowing

from the 11 wells operated by REX Energy along an 8/10 of a

mile stretch of Woodlands Rd.
youngest was 2 weeks old.

I received testimony from a local resident named Gretta. Gretta is

an elderly woman living alone without clean water. She is blind

and uses an oxygen tank. Others are bringing her bottled water

because, as she explained to me, see cannot see when her water

changes colors.

Adding to the confusion, one woman accuses the drilling

company of giving her family test results that state the

compounds where not detected then later discovering in the fine

print at the end of the report that the samples were not tested.

Four residents have also witnessed trucks dumping water on or

near the bridges crossing Little Connoquenessing Creek. Large

bubbled foam has been repetetedly sited in the creek.

At least seven of the gas wells are on land owned by an orchard

operating in Wexford, PA. While there on Sunday I saw several

trucks harvesting pumpkins. When I contacted the general

manager about the issues surrounding the well, he stated
them involved releasing spent fracking fluid. One was a problemwith an impoundment pond. Another for improper or defective

cement well casing and failure to notify the DEP or submit a plan

for correcting the problem. The third was “Failure to properly

store, transport, process or dispose of a residual waste.” And the

forth was for a “stream discharge of 1W (industrial waste).” On

August 31, 2011 REX Energy was cited for “Failure to notify DEP,

landowner, political subdivision, or coal owner 24 hrs prior to

commencement of drilling.” Not only do they have a problem

following the environmental rules apparently, they also have

difficulty with transparency. Why would they place the public in

harm’s way by failing to notify a food producer about possible

contamination of his product before it gets to market? This, in my

opinion, is pure negligence.

And while all this is taking place, the DEP’s own website indicates

only one inspection at the Voll wells.

The effects of fracking on air, water, and soil is completely

unpredictable. In some areas the water table had been raised 20

feet. In others it has dropped 30 feet. It would take me hours to
has not been compromised due to shale drilling but did they

bother to read the report?In the second paragraph of the report the authors state that the

results are limited and do not represent a comprehensive study

nor did it address the cumulative impact of air emissions. In a

nutshell, it was inconclusive. I have included the complete text at

the end of my written testimony.

I did come today to speak on behalf of the people in

Connoquenessing Township but also for myself and my family. At

least 132 new wells and permits have been granted in Butler

county in 2011 alone. Trucks carrying spent fracking fluids will

soon be passing in front of my 13 month-old’s daycare. They are

fracking as we speak at a dairy less than a mile from my

home. This dairy produces milk for nearly 700 schools, including

my 6 year-olds’.

It is clear that the industry can’t be trusted and that there are

fundamental technical shortcomings associated with fracking that
And this is why I am demanding a national ban on fracking

effective immediately. We need to put the burden of proof on the

industry to prove that the process is safe and not on the taxpayers

and individuals to prove that it is not. It is time to step up the plate

and put people before profit and let us make it clear here today

that just as the fiercely independent citizenry of the Great

Commonwealth of Pennsylvania have played a central role in the

formation of our country we will not sit idly by and watch her be

destroyed. We will use the traditions established on the

advancement of liberty in the Revolution against the British, the

rights conceived in our founding documents, and the universal

justice revered by William Penn and we will not be silenced!

Thank you for your time and I will open it up to questions at this

time.
Good morning,

My name is Jason Bell. I’m a resident of Evans City and a Soergels’ regular. Earlier this week I met

several local residents who have been experiencing water problems in the Connoquenessing Township

area. The EPA and REX Energy (the company who is preforming shale drilling the area) have both

tested the water of at least two homes and have found elevated levels of many man-made chemicals in

the well water. The water is black and purple, stains the bathtubs and dishes, and foams out of the

faucet.

One woman’s family was violently ill with vomiting and uncontrollable diarrhea for weeks before their

water turned foamy. Her fingernails have changed pigmentation (called leukonychia) and her personal

physician believes that she has arsenic poisoning. She has been sent for further testing.

Another blind and elderly woman has been left without any water.

A third is being forced to move because here water and soil has been irreparably contaminated. She has

the water tests to prove it.

It s truly a sad situation and all of them blame the sudden changes on the new drilling taking place in

their backyards. There have never been any water problems of this nature in the area and within months

of the start of drilling near their property, these problems began.

Yesterday I was told that the land where the drilling is taking place is associated with Soergels Is this

true and if so have you been made aware of what is happening in Connoquenessing Township? Is there

produce in your market that is grown on this land or any others where fracking fluids are used or

stored? If so do you use well water for watering? Is the water tested?

I look forward to your responses and I hope that you can understand that until my concerns are eased I

will not be shopping at Soergels.

Jason Bell

223 Pattison St.

Evans City, PA 16033

Email from Soergel Orchards

From: Soergel Orchards <folks@soergels.com>

To: ‘Jason Bell’ <trucodiosyahoo.com>

Sent: Monday, September 26, 2011 9:26 AMSubject: RE: Connoquenessing Township

Hi Jason,

Thank you for the e-mail, and thank you for the support of our family’s business. As for the e

mail and information contained in it, I can tell you that we do have land that is leased to REX

Energy, and I do know that water tests from our property have come back unchanged. Beyond
Eric Voll

General ManagerSoergel Orchards

6th Generation

724-935-1743

Northeastern Pennsylvania Marcellus Shale Short-Term Ambient Air Sampling Report

The scope of this short-term sampling effort was limited to several natural gas facilities in

Susquehanna County. Due to the limited scope and duration of the sampling and the limited

number of sources and facilities sampled, the findings only represent conditions at the time of

the sampling and do not represent a comprehensive study of emissions. While this short-term

sampling effort does not address the cumulative impact of air emissions from natural gasoperations in northeastern Pennsylvania, the sampling results do provide basic information on

the type of pollutants emitted to the atmosphere during selected phases of gas extraction

operations in the Marcellus Shale formation. This information will also be utilized to determine if

the scope of the study should be expanded and will identify areas where additional sampling

may be warranted.
Jan Milburn, President Westmoreland Marcellus Citizens

Group

September 27, 2011

The EPA proposal for air regulations addresses a major public health issue.

Gas drilling and related operations have been spewing vast amounts of toxins into

our air every day without limits, sickening families and communities. These

regulations will contribute to controlling air pollution.

According to EPA figures, VOC’s will be reduced by 25%, methane by 26%,

and air toxics by 30% with the implementation of the newly proposed regulations.

However, the question remains as to how much air pollution will be reduced, if at

all, when hundreds of Marcellus wells and accompanying operations are functioning

in western Pennsylvania. For example, if VOC’s are anticipated to decrease by 25%,

but sources increase by 50% or 70% in Westmoreland County, the result would be

an overall increase of pollution and a deterioration in our air quality. Is the

proposed reduction sufficient to offset the anticipated enormous increases?

The EPA advised that the Pennsylvania DEP should consider the cumulative

amount of air pollution from drilling sources, yet these proposed EPA regulations

would not consider aggregate pollution. It is noted throughout the proposedregulations that there are exemptions for minor emitters. In Pennsylvania, smaller

sources do not need to be permitted. Who is responsible for checking these

facilities? Who is designated to test the extent of pollution emitted from theseoperations? If there is no testing, there can be no basis for determining the need for

improved regulation. A 2010 University of Texas air monitoring study suggests

TCEQ ozone attainment modeling under predicted NOx by 20%. Numerous smaller

sources combined can produce the amount of air pollution equivalent to a major

source. Our lungs do not differentiate. Aggregate pollution of all facilities must be

considered.

All gas drilling sites, and other gas operations regardless of the

estimated volume of emissions, should be equipped with air monitors and the

resulting data be made available on a public web site. Gas companies, makingmillions in profits, can afford this basic protective health measure.

No facility, including those categorized as “small”, should be permitted to

operate without implementing the best available technology. It is clear that

without regulation, the industry will not voluntarily utilize best standards as

evidenced by the low implementation rate of the recommendations of the EPA STAR
Task Force, noted that as air improved federal rules allow for shedding monitors,

but we actually need more, not less because we don’t know everything about the

region’s air quality. Nationally, we do not have the “robust kind of monitoring

network we need” according to William Becker, executive director for the National

Association of Clean Air Agencies.

It was noted by experts interviewed in the Post Gazette series that valley

terrain, wind patterns, and inversions can cause pollution to accumulate rather than

dissipate, but nowhere in state or national regulations is terrain, like the

Ligonier Valley where I live, taken into consideration in placing or regulating

gas operations

Under the proposed regulations, flaring will be required in situations not

meeting criteria for reduced emissions completion, unless it is a hazard. Flaring is

a

hazard to human health, especially to our children who are developmentally more

susceptible. Under no circumstances should it be utilized. Flaring is illegal in

some countries. The United States can’t impose health and safety standards that

industries in other countries are already abiding by? If green technology is not an

option then a gas well should not be sited in the area.

I was exposed to flaring for literally two minutes at

a Ligonier well site and

immediately became violently ill. I had stopped the car to take

a picture of the flare

and became sick enough to have to go to bed with a horrible throat that was not just

sore but felt swollen; an indescribable foggy feeling in my head; aching, burning

eyes; and asthma, which is typically controlled. This lasted for several days.

In Ventura County, air pollutants emitted during flaring were measured. It

was found that a host of pollutants can be emitted which may include: benzene,

formaldehyde, polycyclic aromatic hydrocarbons (PAHs, including naphthalene),

acetaldehyde, acrolein, propylene, toluene, xylenes, ethyl benzene, and hexane.

(Ventura County Air Pollution Control District, Leahey, D. Theoretical and Observational

Assessments of Flare Efficiencies, Journal of Air &Waste Management, Vol. 51). Researchers in

Canada have measured more than 60 air pollutants downwind of natural gas flares.

A family in Silt Mesa, Colorado, living near three rigs with ongoing flaring

(the nearest rig being about

1⁄2 mile from their home), experienced headaches,

severe nosebleeds described as hemorrhaging, and rashes. Their doctor advised

them to evacuate their home. Air samples taken on their property showed “levels of

hydrogen sulfide more than 185 times above the long- term level set by the EPA

(2 ug/m3).”

In 2009, Deborah Roger’s whose farm is located in Fort Worth, reported

bothersome odors, but by the time an inspector would arrive, the emissions usually

subsided. “She found it curious that just as TCEQ called to say they were on their
TCEQ Effects Screening Levels. Dr Armendariz of Southern Methodist University

reviewed the findings and advised the family that carbon disulfIde, a potentneurotoxin, was 300 times higher than EPA’s normal limit for ambient urban air.

TCEQ conducted its own tests to determine the extent of exposure to newly

detected compounds and it was confirmed that benzene, toluene and carbondisulfide among other chemicals were being emitted by gas facilities in the Barnett

Shale region. The department detected 35 chemicals that were above “appropriate”

short-term levels. (Texas Oil and Gas Accountability Project, How the Texas Natural Gas BoomAffects Health and Safety, April 2011)

Dr. David Sterling, Chair of Environmental and Occupational Health at UNT

Health Science Center reviewed air testing results taken during flaring of

a well near

the farm and wrote, “The compounds found range from those with acute primarily

irritation issues, to oxygen deficiency potential (i.e., heavier than air and may

accumulate low to the ground and in gullies, displace oxygen, with potentialasphyxiation), to chronic organ toxicity, and known or suspect carcinogens. The

levels during flaring exceeded, in most cases, the Texas Commission on

Environmental Quality effects screening levels, both long and short term, which are

State levels of exposure to air toxins which can trigger adverse health effects.”

The same evening the air sampling was conducted, several of Roger’s

perfectly health baby animals, two baby goats and six baby chicks, died of

asphyxiation. DeBaily, senior veterinary toxicologist at Texas, A&M University,

wrote

a letter of concern to the mayor ofWestworth Village concluding that the

compounds were problematic to animals and human heath as they move up the food

chain in milk and meat. (Texas OGAP, Oil and Gas Accountability Project)

The combustion of VOC’s and HAP’s results in increases in carbon monoxide,

NOx, particulate matter, and other pollutants. Combustion at all gas operationsmust be discouraged. Is the EPA certain that the impacts from NOx are

secondary as stated in the Regulatory Impact Analysis, since NOX is a limiting

factor in the creation of ozone in this area?

Frack pits should be illegal. In nearby Washington County, huge misters

spew toxic wastewater products into the air. Some of the lighter or more

volatile chemicals and compounds, such as benzene, toluene, hydrogen sulfide, etc.,

will escape from the produced water pits into the atmosphere. These chemicals maythen be transported through the air, into nearby neighborhoods. Families living

nearby are forced to breathe these fumes and many are sick.

There are scores of press articles about families who believe they have

experienced health problems due to water or air pollution from the gas industry.

When does the anecdotal become epidemiological data? Only when both state and

federal agencies comprehensively collect, analyze, and collate the data on

The pollution that Marcellus gas drilling will bring to Western PA will, without

question, result in increased health problems. In Westmoreland County and much

of western PA, we are already in a state of non-attainment for ozone. We alreadyhave a high incidence of asthmatic children. We already have high rates of certain

cancers and birth defects. I am deeply concerned that the proposed regulations willnot go far enough to protect health.

According to Scorecard records, compiled by Green Media Toolshed, and based

on 1999 data (Scorecard’s data about criteria air pollutants are derived from U.S. EPA’s Air Quality

System and National Emissions Trend database), Westmoreland County ranks in the worst

90% of counties nation wide for VOC’s, nitrogen oxide, and carbon monoxide. It also

ranks in the dirtiest 80% of counties nationwide for PM 2.5 emissions and sulfurdioxide. In the 2002 rankings related to major chemical releases and waste

generation, Westmoreland County ranked in the dirtiest 90% for total

environmental releases, non-cancer risks, and reproductive toxicants. The county

ranked in the 80 to 90% worst counties for cancer risk and developmental toxicants.

Westmoreland County is not in compliance for ozone standards, and was awarded a

grade of D by the American Lung Association based on ozone pollution.

The Marcellus shale play is perfectly situated to worsen existing ozone and

PM nonattainment in northeastern United States. (Joe Osborne, GASP, Pittsburgh)

Dr. Levy, Joel Schwartz, and Lisa K. Baxter completed a study in 2009, published in

Risk Analysis, that puts values on the health damage from pollution, including

premature deaths. (Post Gazette, Templeton and Hopey, 12-19-11)The study offers a range of health-related damages of $30,000 to $500,000 for every

ton of fine-particle, or PM 2.5 pollution, with a median rate of $72,000 per ton. Foreach ton of sulfur dioxide pollution, or SOx, the health damage ranges from $6,000

to $50,000 per ton, with a median rate of $19,000. For nitrogen oxide pollution, or

NOx, the per-ton rate ranges from $500 to $15,000, with a median cost of $4,800.

Using the median per-ton costs of health damage, the total annual health

damage from the region’s major sources of pollution is $9.4 billion. Such costs are

“external” because they are borne by the public rather than industry. We cannotafford this burden physically or financially.

The Post-Gazette series dealing with the 14 county Pittsburgh area presented

data on air pollution and risks as they exist now, without the additional burden of

1
12-20 10)

Mapping revealed an overlap of disease rates with the 166 major sources

of pollution in the 14 county region. “Based on the latest PM [airborne particulate

matter] data it still ranks as one of the worst urban areas ofthe country

according to John Graham, senior scientist with the Clean Air task Force. “The air is

not clean, and it’s killing people.”

The rate of asthma is far higher than average. Many school districts have 13 -

17% of students afflicted with asthma and in one area district, 37% of students are

asthmatic. Pittsburgh has some of the worst levels of particle pollution and ozone in

the country according to a recent news report. (Jim Parsons, 7-20-11, WTAE) Myron

Arnowitt, Pennsylvania state director of Clean Water Action, said of the asthma

statistics, “This is a public health emergency. I’ve studied this issue. I’ve read the

scientific literature on asthma. Numbers over 30 % are off the charts high.”

Children who live in highly polluted communities are five times more likely

to have clinically low lung function—less than 80% of the lung function normal for

their age. I have two daughters affected by asthma, therefore I know how severe

asthma changes a child’s life, resulting in their missing important childhood events

and interfering with their education, social life, and emotional development. When I

was president of the PTA in Ligonier, the superintendent of schools asked if the PTA

could assist in looking into the high rates of asthma and cancer among employeesand spouses of employees within our district.

Allegheny and Westmoreland counties (and the rest of southwestern Pa)

show higher mortality rates for multiple sclerosis. Westmoreland County

experienced a 41 % increase in MS deaths over a nine- year period. Studies

(including a 2003 Finnish study) conclude that poor air quality may make people

with MS more susceptible to relapse and infection. Allegheny County residents have

increased risks for several cancers including stomach, thyroid, liver, bronchus and

lung, kidney, non-hodgkins lymphoma and breast. I see those statistics personified,having had many friends and family members with cancer and immune diseases. My

children have several friends who have had cancer. They are in their thirties.

Air pollution causes and accelerates cardiopulmonary disease, lung cancer,

and all-cause mortality. A Penn State College of Medicine study found disturbances

in cardiac electrical activities within six hours after an episode of elevatedparticulate levels, raising the risk of cardiac events and chronic heart disease. A

2
implement the following recommendations as soon as possible:

1. All Marcellus gas operations, regardless of the volume of pollution emitted, must

be cumulatively monitored and regulated. Air monitors should be required on all

equipment.

2. Best available technology must be utilized for all processes and activities

involving Marcell us gas extraction, gathering, compression, and transmission.

3. Collective, aggregate pollution levels from all gas operations within a regionshould be considered when establishing new source rules.

4. Flaring and frack pits should not be permitted in any location for any short or

long term duration.5. VOC emissions from condensate tanks must be controlled with vapor recoveryunits.

6. High-bleed pneumatic valves and fillings on the pipeline networks should be

replaced with no-bleed alternatives.

Marcellus gas extraction is clearly a highly industrial activity that is currently

allowed to occur in virtually every local community, near any public or privatestructure, including schools, hospitals, and private residences. These activities

should be the EPA’s highest priority.

Thank you. - (f /_///

Jack W. Milbu n

Ligonier, PA

3
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The proposed new regulations acknowledge the air pollution impacts to my farm and its living

organisms. So 1 would like to say first and simply “Thank you, this is a good first step.”

But in good conscience I cannot say simply that to you, not when you place at the very heart of

these proposed regulations the task of continuing “EPA’s efforts to support responsible oil and

natural gas exploration and production that protects public health and the environment.” That task asstated is a chimera - “an impossible or foolish fantasy.”

The term “responsible oil and natural gas exploration” should be understood as a chimera when

it is used in the context of endorsing the extreme fbrm of fossil fuel extraction known as high

volume slickwater fracturing of long laterals into tight shale deposits. In light of ample andmounting evidence that unconventional drilling is fraught with environmental and public health

perils, the notion that there can be any kind of “responsible drilling” of this kind is a foolish

fantasy unworthy of a government agency such as yours. It enables an industry to operate thatshould be halted until we have conducted a comprehensive, long-term study of the environmental

and public health risks.

There is not any such long-term study. Nor is there any scientific consensus that this type of gas

extraction cannot cause irreparable environmental harm - from above or from below. We allowthis drilling in direct contradiction to the Precautionary Principle.

Your Federal Register announcement admits that “we are not able to provide credible health

benefit estimates . . .for these rules.” If you caimot measure the benefits, it is because you have

not fully measured the risks, yet you allow the drilling to proceed.

You exempt from your rule “area sources”... that have fewer than 10 tons a year of emissions of

a single air toxic and less than 25 tons a year of a combination of toxics.” Does that mean thatthey can escape these new air pollution rules so long as they dump only 9.99 tons of a single air

toxic or 24.99 tons of a combination of toxics on my head, on my land and on our animals?

You say “EPA’s residual risk review found that the current maximum individual cancer risk

from oil and natural gas production — is 40 in I million, which falls within a range EPA

considers acceptable.” And you state these new rules will not so much reduce this rate as keep it

from staying at the 400-in-I million where is now stands. Does this mean that maintaining the

status quo of 40 cancer-ridden people per million is acceptable”?

These are not acceptable conditions under which the drilling should proceed. Until we get firm

data on health risks’, until we make every oil and gas facility of whatever size sublect to rules
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origins of which cannot be definitively traced. Throughout the age of fossil fuels our

government has allowed too many pollutants to poison the atmospheric, aquatic, and biological

resources that sustain all life. We cannot know whether pollutants previously allowed as“acceptable” may have condemned my wife to the suffering she now endures. On suchcalculations as those you have articulated in these proposals, my wife may be one of those whoman earlier panel such as yours deemed acceptable to suffer an early, painful and elongated deathfor the sake of cheap and wasteful fossil fuel energy consumption. There is a high probability

that her cancer belongs on the ledger of some nrnjor industry that our government failed tocontrol adequately, hut of course they will never be found culpable.

Until you call a halt to this irresponsible drilling, all your good work in these air pollution

proposals will serve mainly to enable, endorse and compound the risks of a widespread

poisoning or our environment, Thank you.
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This focus is important because hydraulic fracturing operations are critical to U.S.

energy development. Without this technology — or without the ability to employ it costeffectively — natural gas and oil development could be discouraged, delayed or reduced.

This would be a serious mistake because these fuels are a vital part of our nation’s

energy landscape today and are expected to continue to be in our future. The

administration’s own energy projections show that oil and natural gas are expected to

supply most of our nation’s energy for decades.

Unfortunately, unless properly crafted, these rules could hamper our ability to supply the

oil and natural gas we know we will need. And making the rules work could be difficult.

The comment period for these extensive, detailed rules is too short. Controls would be

imposed on the industry with inadequate lead time. This would make it difficult for

operators to prepare to implement the controls and would increase the risk of

unintended consequences.In the worst case, the result could be requirements that impose a virtual moratorium on

developing U.S. oil and natural gas resources. This would severely hurt job creation

and revenue generation — and harm our nation’s energy future.

We have prodigious reserves of oil and natural gas here in the United States. Oil will

continue to be vital for supplying transportation fuels. And there are large and growing

markets for natural gas related to electricity generation, manufacturing, transportation,

and home consumption. We need to be able to meet this demand. Natural gas is

extremely affordable today relative to just a few years ago, largely because of the shale

gas boom now underway.

More domestic oil and natural gas development, unimpeded by impractical rules, is

crucial for job growth. The industry has a strong track record on jobs as evidenced by

what is happening in North Dakota, Texas, Pennsylvania and many other states. The

industry now supports 9.2 million jobs, and continues to create them. More than 9,000

oil and gas related jobs were created this summer according to BLS, at a time when

new net job creation for the economy as a whole was coming to a halt. Perhaps a

million or more new U.S. jobs could be created over the next seven years if common

sense changes to energy policy were implemented, according to recent research
As for the specifics in the proposed rules, we support green completions where the

operators determine the technology tQ be safe, technically feasible and cost-effective.

However, the final rules should phas’any green completion requirements by including

a significant extension of time for their full implementation.

Specially designed equipment is required to safely perform green completions, which is

both expensive and time consuming to build. Insufficient reduced emission equipment

is currently available and cannot be constructed before the expected second quarter

2012 compliance date.

Furthermore, the proposed regulations do not account for challenges relating to several

current completion technologies and known reservoir properties. For example, there

are technical issues regarding certain coal bed methane technologies, low pressure

reservoirs, and reservoirs with very low volatile organic compound content.

The final rules should also recognize that thousands of “tank combustors” will be

required to be certified and manufactured to reduce emissions. These combustors willnot be available early next year. The final rules should recognize that additional time is

necessary before this requirement is imposed.

Lastly, EPA should simplify the overly burdensome aspects of the notification,

recordkeeping, monitoring, reporting and performance testing requirements in theproposed rules to reflect that many of the industry’s sources are at remote and

unmanned facilities.

In closing, we believe the Agency should allow an additional 60 days for the public to

provide comment on this important rulemaking for the following reasons:

• The proposed rules are expansive and complex. This is a set of five complex and

interconnected rules. Indeed, the proposal spans over 100 pages in the Federal

Register and the docket contains many times more pages of supplemental

analyses and materials. Preparing comments on any one of these rules would be

a challenge within 60 days. Preparing thorough and meaningful comments on all

five within 60 days is not reasonable or practicable.
already seems clear that EPA has significantly underestimated the cost of

implementing the proposed rules. For such a far-reaching set of rules, it is

imperative for affected companies to have the time needed to thoroughly assess

the economic and other analyses underpinning the proposal.

Again, we do not fundamentally oppose green completions where they make sense and

the operators have sufficient time to implement the controls. However, given the

complexity of the issues, the many competing demands on Agency resources, and the

time that will be needed to respond to public comment and complete interagency review

of the draft final rules, we also believe that a one-year extension of the final rule

deadline for completing these rules is appropriate and justified.

API will be submitting detailed comments before the comment period closes and API

looks forward to working with the EPA on safe, achievable, and cost-effective final rules.

That concludes my comments. Thank you.
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September 27, 2011

TESTIMONY OF DOUGLAS A. SHIELDS

MEMBER, PITTSBURGH CITY COUNCIL

EPA Hearing, Pittsburgh Pennsylvania

In Re: Proposed EPA rule Change (40 CFR Parts 60 and 63) Oil and Gas Sector:

New Source Emission Standards for hazardous Air Pollutants

The EPA is charged with protecting, We the People, from harmful exposures to toxic

substances introduced into the environment largely due to industrial and commercial

activities and processes.

By law, you are charged with creating emission standards to provide an ‘ample margin”

of safety that protects the public health and applies to the level of “individuals most

exposed.”

Volatile Organic Compounds (VOC’s) have long been known to be harmful to people as

well as other life forms that live among us. This rule is long overdue.

I thank the EPA for promulgating this new rule. Flowever, you are here today not

because you did your due diligence and acted proactively. You are here as a result of

citizens filing a lawsuit alleging that you failed to meet your obligations to do your job.

This is a concern of mine and the people I represent in the City of Pittsburgh. The EPA

cannot simply he a spectator to what is going on under its nose. The people of this

country fund the EPA to do its job while we go about our daily lives and do ours. My

thanks go to those citizens who went to court to get you to do what you were supposed to

do in the first place.

There is no cogent regulatory environment to manage or protect us from the adverse

effects of shale gas exploration in Pennsylvania and throughout shale plays in the United

States. I have reviewed the proposed rule and find it to be meaningful and helpful. The standards of review for making this new rule are clear and the proposed rule is consistent

with the core mission of the EPA and the laws and regulation already in place. The costbenefit analysis is sound and logical.

510 City-County Building • Pittsburgh, PA 15219

112.25S.8965 (p) 412.255.0820 (f) doug.shieIdsDcity.pittsburgh.pa.us
analysis. While you have already set forth the evidence that these standards are

attainable, they will still argue that this is going to kill jobs when, in fact, not enacting this rule change will kill people.

Be advised that gas drilling operators in Pennsylvanian are making profits beyond our wildest dreams. Range Resources, for instance, reports in their 2010 Fourth Quarter results that they have “86% oftheir capital budget” in play in Pennsylvania Marcellus Shale operations and are making a 50% rate of return on their investment. Other

corporations are making similar profits as well. The race is on for them to extract as

much gas and reap the profits without regard for the health, welfare and safety of the people of this state.

The gas industry invokes a variety of sound bites that, upon analysis, mean nothing.

For example, I hear things like “this is a game changer.” Well, I would like to know

what the game was and what it is now.

I hear: “this is a bridge /itel” without any clear public policy as to where this so-called

bridge is taking us.

I hear: “we have to do this responsibly” without any iteration on their part how they define responsible and what they will do to act responsibly.

I hear the “jobs and money” mantra without warning that our health is threatened.

They claimed they were not the source of bromides in our rivers, which serve as the

region’s primary drinking water supply. This changed only last March when conclusive

evidence was provided by Carnegie Mellon University researchers. They claimed that there “has not been one documented case of drilling fluids, injected into the ground that migrated hack into a drinking water source.” In fact, a documented case was found in a

1986 EPA study.

There is a laundry list of water and air source contamination directly linked to the activities of the oil and gas industry. For example, the case of Dimmock, PA, where abad well casing installed by Cabot Oil was proved to be the cause of Dimmock losing its potable drinking water. They have yet to find relief. Cabot Oil denied culpability until proof was provided. I could cite many more examples.
with gas exploration and mid-stream activities. The industry continues to deny their role,

yet civil suits are settled and confidentiality agreements are made, thus shielding the public from full disclosure.

Finally, our institutions of government

— local, state and federal - have failed to act in the

public’s best interest. The industry has armies of well-heeled attorneys who obfuscate

and offer excuses as to why imposing this new rule is the wrong thing to do. The oil and

gas industry’s credibility on the subject is non-existent. I hope the EPA will not give

great weight to their testimony; to the contrary, you should look upon their empty words with a jaundiced eye and place the burden of proof on them

— not on me or my fellow citizens.

We, the people, have no access to cogent advice or legal advocates to argue on our behalf. No one has taken this proposed rule to the public to explain it. Our statelegislature has held no hearings to provide meaningful information to help us assess the risks and make well-informed decisions.

This proposed rule represents only a start in efforts to preserve our rights as citizens, to

preserve our health, welfare and safety. I endorse it. I do want to inform you that you

are a decade late in doing so and there is so much more to be done. The horse is already

out of the barn.
I wanted to take a moment to talk with you about some of the things that I have

seen over the past year with regard to people in my area who have been having

problems with air emissions from shale gas drilling and processing facilities.

The first is a case of a family in Avella Pennsylvania. The family lived on a 10 acre

strip of land that was surrounded by land owned by a neighbor. Their neighbor

leased out her land, resulting in a wide array of drilling and processing facilitiesright along the border of this family’s property. There were several wells,

numerous compressor stations, a dew point control facility, a wastewater

impoundment, as well as condensate tanks. I first got to know this family in

winter of 2010. In my first visit there, I smelled a light, sweet smell in the air — a

scent which I later learned was the smell of benzene. Within the two hours I

spent outside, I began to feel lightheaded, confused, and headachy. I later

learned that this was a common way to feel on their property, and that it was a

feeling the family encountered on a daily basis. Over time, the symptoms they

experienced increased, and included dizziness, vertigo and massive nosebleeds.

This was experienced not only by adults but by their two elementary-school-aged

children who were also exposed. When an air testing expert went to their

property to try out his equipment, before he had even walked down the drivewayit was already reading off the charts on the level of benzene in their air.Ultimately the family had to leave the property for their health’s sake.
they are no longer drinking the contaminated water, they and a number of their

neighbors are having significant health problems. (I don’t know all theirneighbors — I’m only recounting information on the ones whose situations I’m

aware of). On this one street, residents are experiencing nausea, vomiting,diarrhea, seizures, bleeding from various orifices, weakness and heaviness in their

legs, rashes, hair loss. My friend had a seizure a few weeks ago and was taken to

the hospital. Her dog had a seizure at approximately the same time. Her dog wasdiagnosed with bone cancer and had to be put down. Her neighbor across the

street has bone and skin cancers. A man down the street is bleeding from various

orifices, a woman up the street has 2 cats that are bleeding from their noses. The

last time I was there, perhaps 3 weeks ago, there was a dense, slate-blue colored

fog over the whole area. I began to feel lightheaded, headachy, drowsy and

confused. A colleague who was there with me at the time felt the same way and

was also nauseated. One of the neighborhood children — my friend’s relative -was at home vomiting from the fumes.

Other people I know live near Lake Lynn, Pennsylvania. This particular family lives

in a valley with a leaking “Christmas tree” gas well and several condensate tanks

on the hill above them on one side, and with four or so compressor stations about

Y mile down the road from them, up on a hill on the other side. The mother andgrandmother trade off each night, with one staying up and the other sleeping,

because they’ve had experiences where these facilities suddenly began to spew

gases over their home. They are afraid that they will be gassed in their sleep and

won’t be able to get their children out. A scientist friend of theirs said that they

should also be concerned because the gases are explosive. Last fall they had a lot

of problems with a cloud of gas that would circulate through their yard in the

early evening, when the air became cool. (When the air cools, it tends to push
from being outside, due to the fumes that settle in their area, they have blisters in

their noses from standing out in the morning, waiting for the school bus. Several

of their children have high blood pressure. They had had air tests run that

showed significant levels of volatile organic compounds in their air. Their blood

tests also reflected this exposure. On this thumbdrive, which I will leave with you,

you will find a file showing the emissions coming off of the compressor stations at

Lake Lynn, Pennsylvania. I asked an environmental scientist to review this video.

She commented:

“There are a large number of point source emissions as well as fugitive emissionsources.

The chemicals most likely being released from these sources are volatile organics

such as benzene, ethylbenzene, xylene and toluene. In addition a large number of

hydrocarbons such as methane, ethane, etc.

The health impacts described as being experiencing are consistent with thechemicals normally emitted from such a facility. The emissions from

this compressor station could be controlled by technical devices.”

Up in Evans City, PA there are several other families a friend and I recently visited.

At the time that I was there, a well was flaring about a mile away. You could hearthe “jet engine” sound very easily when you stood outside. There was also a

wastewater impoundment nearby (which also off-gasses toxic fumes) and several

other wells and processing facilities close to the house. It was a humid day, which

pushed the fumes closer to the ground than might otherwise have been the case.

While standing outside in their yard, I began to feel lightheaded and headachy,and my nose began to burn. My friend’s throat also began to burn and she began

to feel nauseated. Even after we stepped inside, my head continued to throb and
their living room floor, and hemorrhaged, bleeding from all its orifices before

dying in a pool of blood.

After visiting this area for about 3 hours it took me a good 10 hours to feel normalagain. It took my friend two full days to recover.

None of these sites use even the existing technologies to control emissions.

Instead, the more rural you go, the wilder it becomes, as people are exposed to

fumes in both composition and volumes that would not be permitted by any

other industry. Several of these families have had air and blood and/or urine

tests run, and it is not uncommon to see the chemicals that are showing up in

their air also appearing in their blood and urine.

Last year I had a conversation with Helen Humphreys, formerly of the DEP. She

stated that one of the challenges with air quality and this industry is that the legal

limits for air-borne exposure to these chemicals exceed the limits needed to

produce negative health impacts. Generally speaking, as I understand it, the legallimits are based on occupational exposure — i.e. 8 hour day/ 5 day/week —

exposure, not 24/7 residential exposure. Consequently, we can legally beexposed to levels of industrial chemicals that will harm our health.

I strongly urge the EPA to take the most aggressive steps possible to change the

laws, to change the regulations, and to put into place the appropriate protections

to protect American citizens in Pennsylvania and elsewhere in the country from

If happiness is the only good, he has not found it in the possession ofthe conveniences or

luxuries. He was closer to the contentment on horseback in the wilderness than he is in a jet plane in the skies. He has conquered the world, but not himself,

This new continent you showed him from what was left of your creation is now despoiled by his avaricious nature. He has dug the gold and silver from you hills, cut down the forest that

processed the oxygen he breathed, and populated the land with people who lived in a complex of impending disaster

The clean streams have become open sewers to carry his effuse out to the sea, and marine life

perishes in the estuarian kindergartens from pesticides. He is facing a spring that will be silent, for birds are passing away in the poisonous environment that has replaced the primitive wilderness. They drift into shore on waves, embalmed in oil, or their eggs are infertile from the chemicals of death that pollute the land, air, and water.

There is

a pessimism in truth and terror in prophecy. Perhaps what we see happening in your world,

0 Great Spirit, is a design-a final plague foreshadowing the destiny of man; or I may be thinking with embittered thoughts, a man who is no longer young in such a thoroughly finished world.

If our society is death-oriented, as Szent-Gyorgyi, the Nobel Prize-winning scientist believes, the conclusion of man’s life on earth is inevitable, but I cling tenaciously to the hope that he has the perception and will power to overcome the evils he has fostered. He has the skill to remake the

world if he possesses the desire; and it may be that youth, which is in revolt against the establishment, will quit floundering in ftitile exhibitionism and direct its energies to objectives that are imperative in the struggle for survival.

0 Great Spirit, instruct the children ofthe White man in his wisdom ofthe past and the futility of the hours when they become lost in the wilderness of fmstration. Counsel them to venerate truth and its companion virtues. Teach them to appreciate the simplicity and wonders ofNature, and to

protect its wildlife against insensate tyrannies; and as they grow to maturity, let them learn the shattering uselessness of conflicts and wars that indict their ancestors. Give them the formulas

for freeing the air, water, and land ofthe poisons that have traumatized their environment.

From your creative hands, you gave my people a Garden of Eden between two oceans. The

worshiped you with their eyes, their ears, and their thoughts. The flower and blade of grass spoke to them, and your songs were heard on the violin strings ofthe wind in the trees.

The Indian people you put here weep for what has happened. They have a sturdy background of morality and discipline. Forgive those who tried to remake them into the image ofthe White

man, and let the wealth of their heritage be preserved as a vital force in the world and not entombed in museums or consigned to oblivion.

This is my prayer

Chief Red Fox
Office of Air Quality Planning and Standards,

Sector Policies and Programs Division (El43-05)

Environmental Protection Agency

Research Triangle Park

North Carolina 27711

Re: Oil and Natural Gas Sector: New Source Performance Standards and National Emission

Standards for Hazardous Air Pollutants Reviews; Proposed Rule, Document ID: EPA-HQ-OAR

2010-0505-0002, Docket ID: EPA-HQ-OAR-20 10-0505, RIN: 2060-AP76

To whom it may concern,We submit the following comments concerning the proposed rule for Oil and Natural Gas Sector:

New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants

Reviews. The Allegheny Defense Project (ADP) is a not-for-profit organization based in theAllegheny National Forest with over 3,000 supporters who boat, fish, swim, camp, cross-country

ski, and recreate in and along the Allegheny Reservoir and in the Allegheny National Forest (ANF).

ADP works to protect the Allegheny River and reservoir, and the watersheds feeding the reservoir.We work to protect these lands through grassroots organizing, research, education, aerial and on

the-ground monitoring, participation in the public decision making process, litigation, promoting
Unfragmented forest in

Vermonts Green Mountain

National Forest.

Clearcuts, roads, pipelines,

and oil and gas wells in Elk

County, ANF

The ANF is the most industrialized forest in the USFS system.

Every year, the oil and gas industry drills and fracks more than 25,000 wells across the country. In2010 and 2011 alone, 1,100 wells were drilled in the four counties ofthe ANF. There are currently

12,000 to 15,000 active oil and gas wells on the Allegheny National Forest, including associated

pump jacks, tank batteries, equipment storage sites, generator and compressor stations, open brineand fracking pits, water impoundments, water transport lines and pumps, gas and oil pipe lines, and

2,236 miles of OGD roads on top of 1,512 miles ofsystem roads. The density ofthese wells is

often at 500 foot spacing (See figure below. Each green dot is one well). In these stripper-welldevelopments which use hydraulic fracturing in their drilling process, this density is described as

“full mine out.”

Allegheny Defense Project, 117 West Wood Lane, Kane, PA 16735

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In figure above each green dot is one well. This is “full mine out.”ADP learned in 2009 as part of a National Environmental Policy Act (NEPA) process that was

initiated on the ANF for private oil and gas well drilling that the USFS predicts that there will be

“full mine out” on 2/3 ofthe ANF. Yellow areas in figure below are predicted for “full mine out.”

Allegheny Nationa’ Forest

Transition Enviromental Impact Statement

Part II Area

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Figure above shows “full mine out” well spacing on the ground.In addition to the “conventional” oil and gas drilling now the ANF is begining to see

unconventional shale gas drilling. There are at least fourteen permitted or drilled Marcellus shale

gas wells within the ANF proclamation boundary. The first three Notices to Proceed for Marcellusshale gas wells for operations on ANF lands have been issued and the first two wells have beendrilled. Royal Dutch Shell has begun drilling unconventional shale gas wells on the ANF andPennsylvania General Energy and National Fuel Gas (Seneca Resources) are drilling these shale gas

wells on state land in-holdings (i.e., gamelands). The state forests in the area are also being hit hard

by the industry with EOG Marcellus shale wells now fragmenting the Moshannon State Forest arid

Elk State Forest lands adjacent to the ANF.

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ADP has monitored these sites during different stages of their operations. The massive imprints of

unconventional shale gas drilling operations—15 to 20 acres per site, without taking into accountthe underground disturbance from hydraulic fracturing with horizontal wells radiating out one mile

in multiple directions from the bore hole—clwarfthe shallow well developments that havedominated the landscape to date. Each well uses between 5 and 10 million gallons of fresh water(consumptive use—unavailable for future use because of contamination), which oil and gas

operators seize from surface streams or aquifers. This drilling and fracking water is then polluted

with industry chemical additives (some carcinogenic) and is also contaminated with highconcentrations ofsodium, chloride, bromide, arsenic, barium, other heavy metals, and

radionuclides.

Allegheny Defense Project, 117 West Wood Lane, Kane, PA 16735

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Figure above illustrates shale gas drilling on state lands adjacent to the ANF

All ofthis industrialization and destruction of our natural areas, our communities, and our homes

has impacted public health.

We commend the EPA for taking this step, but it is long overdue. EPA must not delay the proposed rule. The industry has had enough time to live by the old rules, which have facilitated damage to the

health of our families and communities.

The case ofthe Allegheny National Forest clearly supports the need for the EPA to consider

cumulative impacts. The problem isn’t one oil and gas well, but rather the thousands of wells and

infrastructure across the landscape. These rules take a big step forward in addressing those

cumulative impacts, but the EPA must ensure the collective impacts of oil and gas drilling are fully

addressed.

The proposal should ensure a consistent level of air quality protection nationwide. Some states,

including Colorado and Wyoming, have already taken steps to protect air quality from oil and gas

drilling. These rules will ensure other states realize the same benefits. The EPA must ensure that wehave a consistent floor of protection across the country.

The EPA must strengthen the proposed rule:

• As the oil and gas industry is one ofthe largest sources ofmethane pollution, this rule must

require direct methane reductions and controls.

• Hydrogen sulfide is a dangerous air pollutant with significant health effects to all who are in

contact with it. This dangerous gas is currently ignored and must be addressed immediately.

• The oil and gas industry must not be allowed to “flare” or burn-off un-captured gas as this is

still a significant source of air pollution.

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the public’s safety along with our food and water supplies.2. There are not enough DEP inspectors per well site. Currently, there isonly one inspector for approximately every 101) wells. Each community

should have their own inspector.3. Distances between well sites and private water wells should he

increased. Distances of well site to property lines, wetlands, streams, etc.

need

reviewed.

4. Flaring of wells must he monitored for pollutants and radiation being

released into the atmosphere.

5. Well sites obtained through eminent domain should provide property

owners with aopropriate compensation for loss arid use of land.

6. Noise levels at well site, compressor stations and process plants must

be addressed along with lighting and hours of operation to reduce disruption

to local communities. A welt recently drilled on a nearby property to my

home caused a 5 week disruption to our sleep due to both noise and ligrting.

7. Retention and removal of fracking fluids — Locks must be installed on

tanker trucks at the valve and removed on1y by a person at the delivery pointto be registered arid documented at point of arrival. Western

Pennsylvania’s geology does not lend Itself to deep well injection. The recent

incident

at a treatment plant along Black Lick Creek created high levels of

contaminants dispersed into the creek.

8. Discontinue the use of diesel fluids and ot:her carcinogens as tracking

agents. Require the drilling companies to provide a list of all fluids used

in their fracking process. This list should include proprietary chemicals

due to the concern for public safety and health.

9. Swift investigation and appropriate compensation should be made

available to property owners experiencing contamination, loss of water, etc.,

due

to nearby drilling.

10. Proper instaliation of well casinas is necessary to avoid leaking offrack fluids into private wells. Inner and outer metal sleeves with ASTM

requirements should be used along with proper grade and specificatIon ofconcrete including proper depth.

11. Temporary, on—site housing of workers should not be permitted due to

health and sanitary concerns.

12. The amount of freso water used in t’-ie fr-ackirq and drill log process

can be in the millions of gallons. NONE of this water is ever reclaimed or

recycled for future use. Although power plants and other industries also use

large volumes of water, nearly 1005 of that water is and can be recycled.

13. Truck traffic and road damage must he monitored and inspected. All

vehicles, regardless of state of registration, shouid be locally and routinely

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compensation should be set for landowner based on fair market value ($1

per lineal foot is not appropriate)

16. Pirst responders must be trained to handle potential accidents at well

sites arid transmission lines, along with any and all other sites treatingor handling the transportation or treatment of waste materials.

17. Once this gas is produced, where is it going? Over 85% of this gas is

planned to be pumped to Louisiana, converted to LNG and shipped overseas.

Why are we not planning to use more of this resource here?

16. How is the radiation connected with the gas by-product being removed

at the processing plants for our safety? Will the remaining radiation levels

meet health arid safety standards nearby the processing plants?

19. Wells should not be drilled near schools, hospitals, etc. Mamont

Elementary School, Washington Twp., Westmoreiand County, is approximately 1

mile from the Beaver Run Marcellus operation. The high school complex is

approx 1nately 1 mile from McCutcheon Enterprises, waste carriers for the frack

f in Id.

20. The Beaver Run Reservoir operation has approximately 15 operating

wells with 45 additional wells proposed. How safe is the tracking process under

and around our community’s main drinking water source? Will it cost us thesafety and health of our water supplies?

21. Drip pans are needed at condensate tanks and other containment, tanksor vessels with a 15% additional volume capacity to prevent accidental

spills. Shrouds with breaching, fan and scrubber need to be employed to capture

toxic gas emissions at wells, condensate tanks or other vessels omittingtoxic gases.

22. Rubber liners installed at well sit:es need to be removed with care and

supervision along with toxins contained within, not bull—dozed into the

land as is the current practice.

23. Reclamation of property owner’s land is essential to return propertiesto original state when well site equipment is removed. This should include

the replacement of topsoil, grass, trees and shrubs which may have been

removed, etc. Many landowners are left with 10 or more acres of toxic shale

waste.

24. Property values are declining in areas where Marcellus drilling is

occurring. Already mortgage institutions are beginning to refuse the lending

of mortgage monies due to the proximity of Marceilus operations to the

property. Residents will begin to leave Pennsylvania in favor of states with

appropriate regulation to protect their citizens.

25. Many of the well site workers are out—of-state and do not pay taxes toPennsylvania. We need to ensure that their incomes are being taxed and

collected in Pennsylvania. We also need to encourage the hiring of more local

community residents.

http://mai1.aoI.com/34122-111 /aol-6/en-us/maillPrintMessage.aspx 9/26/2() ii
creates pollution just as the coal industry. The coal industry localizes

environment damage to mine sites, coke plants, power plants and disposal of fly

ash.

The gas industry proposes to drill under our homes and farmlands using the

horizontal fracking techniques which can eventually jeopardize and

compromise the safety of our ground water and food supply. With the radiation,

bromides, heavy metals, etc. being emitted into the water and air during thedrilling processes, we need to be concerned for our future health and safety.Our ozone levels locally coild potentially become higher than those in Los

Angeles if unregulated.

The oil and gas industry must install proper air and water pollutionequipment such as scrubbers, water clarifiers, dust collectors, etc. Other

industries have been required and provided these safety measures. Why not oil

and gas?

Thank you for your attention to my concerns.

Andrew Pollak

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