Our Aquifers Are Not Bathtubs, and Our Communities Are Not Covered by Glass Domes

Say No to Shale Gas Development and Export Tar Sands Pipelines: Our aquifers are not bathtubs, and our communities are not covered by glass domes.

SUBMISSION TO NEW BRUNSWICK COMMISSION ON HYDRAULIC FRACTURING Submitted on Nov. 20, 2015 by Mark D’Arcy, resident of Fredericton, New Brunswick

SUMMARY

The cost to human health, our air and water, our global climate, and our local economy are simply too great to remove the moratorium on shale gas. Regulations are unable to protect us from the certainty of air pollution in the low-lying valley of Fredericton. And the aquifer from which we draw our drinking water extends far outside the Fredericton city limits into large tracts of shale gas exploration areas.

We have no choice. Climate change means that our communities must rapidly transition away from fossil fuels. The huge greenhouse gas footprint of both shale gas development and tarsands expansion means that both have to be stopped.

And an equally compelling reason to stop shale gas development and tarsands expansion is the destruction our watersheds and airsheds by shale gas fracking, tarsands pipelines, and tarsands export terminals.

Using local matters of concern here in Fredericton, I would like the Commission on Hydraulic Fracturing to recommend that the moratorium on shale gas development remain in place throughout New Brunswick so that no community has to be placed in harm’s way.

RECOMMENDATION #1: Since the majority of residents and communities in New Brunswick get their drinking water from groundwater, we must insist on accurate aquifer mapping before any shale gas exploration and development.

RECOMMENDATION #2: Protect the airsheds of our communities from the heavier-than-air toxic chemicals that would concentrate in low-lying valleys.

RECOMMENDATION #3: Protect our homes, businesses and communities from the risk of damage due to earthquakes.

RECOMMENDATION #4: Vote in progressive candidates into town and city councils that will take advantage of the huge job opportunities of the local, clean economy. BACKGROUND

Politics has no place in human health and safety. Politicians and other decision- makers have a duty of care not to put the public in harm’s way. Citizens concerned with climate change have successfully used duty of care in The Netherlands and in the State of Washington to force their governments to implement stricter reductions in greenhouse gas emissions.

Our current political system has been corrupted by the money and influence of the oil and gas industry. Perhaps the most shocking example of intentional misrepresentation and deliberate censorship of information in the latest report on shale gas fracking written by the United States Environmental Protection Agency.

Why are we going through this process again, just over a year since the September 2014 provincial election? A decisive majority - 2/3’s of New Brunswick voters - rejected the pro-shale gas platform of David Alward’s PC government and the new Liberal government imposed a moratorium on shale gas. Yet here we are with another shale gas commission here in New Brunswick.

Why are New Brunswickers asked to waste their time and energy, their social capital that could be used to contribute to our communities, on yet another shale gas commission? We need to get on with the huge job opportunities with local, diversified economies using efficiency, clean energy, local food production. And we may just save our own children from a catastrophic climate future!

We have run out of time because of man-made climate change. We have no choice but to rapidly transition off of fossil fuels. Our children will not forgive us if we don’t act.

Here is the question I raised with Dr. John Cherry, a world-renowned hydrogeologist and Chair of the Council of Canadian Academies Report on Shale Gas in 2014. This is Dr. Cherry’s response when he was here in Fredericton during his public presentation at the Charlotte Street Arts Centre on Tuesday night at Nov. 17, 2015.

QUESTION (Mark D’Arcy): “The City of Fredericton is surrounded by shale gas license areas 10 km in all directions. The areas not under license areas are the south side of Fredericton and St. Mary’s First Nation on the north side. Everywhere else is in a license area but real estate companies do not disclose this when they sell houses in lease areas. In Fredericton, we don’t know the extent of our aquifer outside the city limits. How can gas companies safely stay away from our groundwater sources when accurate aquifer maps do not exist for most of the province? Since the majority get their drinking water from groundwater, should we not insist on accurate aquifer mapping before any shale gas exploration and development?”

ANSWER (Dr. John Cherry): “Well of course. Shale gas, or no shale gas, you the public should be insisting that our governments get up to modern standards on groundwater monitoring and mapping. And we have done almost nothing for the last 20, 30 years with all the government cutbacks. because the benefits are always in the future. And so in essense, almost all provinces without esception, basically I would put in the category of 3rd world country standards when it comes to groundwater mapping and monitoring. And many people now are now recognizing this crisis and there is kind of a movement to do something about it.

The Federal Government stays away from that action because it is convenient for them to say it is the job of the provinces. As long as the Federal Government is not there, the provincial government is sort of left hanging there.

In many cases the question is if you wanted to do proper mapping and monitoring, how would you do it? And so my position is that the public certainly should not approve of fracking if in fact that task isn’t first completed. And that is a general task. You have to understand your aquifers first before you can decide how to monitor them for shale gas development.”

The Department of Natural Resources map showing the shale gas test drilling license speaks for itself. This license covers a 10-kilometre radius around Fredericton and includes the UNB Woodlot and most other areas of the City of Fredericton and surrounding communities. Just think about what this map represents. Well pads can be located inside the city limits. And well pads can be located outside the city limits and then drill horizontally up to 1 kilometre or more inside our municipal boundaries.

Fredericton is in the center of a huge aquifer under the Saint John River. The significance of this is very simple. Any water contamination by shale gas development that happens to any part of the aquifer affects every other part. The Fredericton Aquifer is not an isolated bathtub of water but instead it is connected to the deeper portions of this aquifer via bedrock fractures underneath Fredericton. The aquifer under the Saint John River Basin is protected and there must be a total ban on any shale gas operations in this Basin.

And the aquifer from which we draw our drinking water extends far outside the Fredericton city limits into large tracts of shale gas exploration areas.

There is limited knowledge on where our drinking water sources. We don’t fully understand the water cycle between the surface water bodies (e.g. streams, rivers, lakes, wetlands) and groundwater systems (aquifers, which happen at various spatial and temporal scales).

The amount of groundwater stored in the aquifer under the Saint John River Basin is virtually unknown. Does the groundwater flow system belong to shallow, intermediate, and deep aquifer systems? Is there connectivity of multiple aquifers? Have geophysical surveys been conducted to discover evidence of bedrock faults that might contribute to recharge from below the shallow aquifers?

Other gaps in knowledge include recharge rates of aquifers, intrinsic vulnerability of regional aquifers, and long-term data and sustained monitoring of groundwater levels and groundwater quality. To protect our aquifers, our municipal and provincial government must work together to ensure the following:

1. To strengthen the protection of our wetlands;

2. To increase our aquifer mapping and groundwater flow monitoring to determine the extent and the connectivity of the aquifers; and

3. To implement province-wide, watershed-based source protection of our drinking water (the same as Province of Ontario implemented after the Warkerton water contamination tragedy)

A critical question for professionals is the following: Will qualified engineers in New Brunswick sign a letter that says #shalegas #fracking will not contaminate our aquifers, watersheds & air?

Engineers and geologists are professionals who are obligated to follow their Code of Ethics of their professional body. An important part of this code of ethics is to protect the public. In New Brunswick, the APEGNB Code of Ethics clearly states this obligation to "hold paramount the safety, health & welfare of the public" (Section 2.1, APEGNB Code of Ethics, retrieved at http://www.apegnb.com/en/home/memberbenefits/publications/codeofethics.asp x)

And do we want to risk the migration of natural gas and fracking fluids into aquifers by the fracking of our bedrock? Industry and government studies show that hydraulic fracturing create fractures that can spread up to 2,500 feet underground, and that hydraulic fracturing can also open up natural, pre-existing fractures in the bedrock.

Early evaluation of the chemicals in fracking fluids is cause for great concern. More than a third of the chemicals are associated with cancer, endocrine disruption, reproductive disorders, and genetic disruptions. And more than half of the chemicals are associated with immune suppression. THIS REPRESENTS EFFECTS ON EVERY ORGAN SYSTEM IN THE HUMAN BODY. And this is only the small percentage of the chemicals that have been identified.

But our government protection of wetlands and watersheds has been systematically dismantled in New Brunswick. On March 16, 2011, more than half of our wetlands in New Brunswick are now completely unprotected from shale gas development. Wetland alternation permits and environmental impact assessments are no longer required for wetlands that do not appear on this present map. And on July 13, 2011, the water classification program has been shelved after a decade of work by 19 watershed groups around the province. This would have provided the regulatory framework for watershed protection here in New Brunswick.

Current environmental policies and aquifer mapping can’t protect our drinking water from shale gas dev’p:

- removal of 100s millions of gallons of fresh water from our natural water cycle

- fracking will widen natural fractures and create new fractures in, and between, shallow and deep aquifers

- release of radioactive fracking sand and toxic fracking water into deep underground drilling wells

- weak wetland protection policies throughout the province of New Brunswick

- no province-wide, watershed-based source protection of our drinking water.

The fundamental public health and safety obligations to the public.

- there is a duty to protect citizens from unnecessary & easily avoidable health risks

- there is a duty to protect waterways, groundwater from contamination

- and there is a duty to preserve & restore forested wetlands to protect our properties from climate change

Here is a brief overview of watershed-based source water protection. Essentially, this is the protection of our drinking water based on watershed boundaries, not municipal boundaries.

All the source water protection should be trying to understand the groundwater flow system. This would require 3 major monitoring programs:

(1) Define the aquifers, including both shallow and deep aquifers. Any systematic program would need to ACCESS, MAP, and MONITOR these aquifers.

Right now our mapping is incomplete.

(2) Characterize the interaction between groundwater and surface water.

We need active, monitored stream gauges that show what happen at the surface. This is because the water flowing over the surface has a direct effect on how near- surface and deeper aquifers recharge over time.

(Note: Measurement of the groundwater recharge system does not mean that you understand the groundwater flow system. You can do a 100 different measurements and still not understand the recharge flow system.)

(3) and model long-term effects.

Unfortunately in New Brunswick we do not have aquifer mapping that shows the extent of our aquifers. In a municipality like Fredericton, we know the 25-year recharge area that is defined as the Wellfield Protection Area. For most aquifers in this province, there is no mapping data.

These are the 36 conservation authorities in Ontario, each mapped out according to a large regional watershed boundary, not municipal boundaries.

Watershed-based source water protection was put in place in Ontario in response to the Walkerton tragedy. While not perfect, Ontario has certainly increased their mapping and monitoring of drinking water sources.

The Province of New Brunswick is a long way off from having this baseline data. Until we have a fundamental working knowledge of the extent of our aquifers, and our groundwater flow system, we should have a ban on shale gas development. It would be negligent to allow huge withdrawals of water, together with hydraulic fracturing of our underground geology, without this information.

How can you accurately allow these test exploration areas to take place if you don’t have accurate aquifer/ground water mapping?

Our Town and City Councils should show leadership by the following:

(1) to adopt resolution asking the Union of the Municipalities of New Brunswick (UMNB), and the Provincial Government, to maintain the moratorium on shale gas development in New Brunswick; and

(2) to adopt resolution asking the Provincial Government to implement watershed- based source protection for our drinking water throughout the province.

And certainly any action we take to protect our drinking water will also have the added advantage of making our cities more resilient against climate change.

RECOMMENDATION #2: Protect the airsheds of our communities from the heavier-than-air toxic chemicals that would concentrate in low-lying valleys.

Shale gas is an issue for Fredericton residents. There never was a moment in Fredericton’s history more important to our quality of life than the issue of shale gas. Unless you cover our city in a dome, air pollution from shale gas wells and pipelines that impact human health is a certainty. I am talking about shale gas development outside of Fredericton that will impact the citizens of Fredericton.

It is an issue with the parents of children with asthma.

And it is an issue for a growing number of residents like myself who read the health reports now coming out about the certainty of air pollution from shale gas operations, especially for residents living in a low-lying valley such as Fredericton. We now know that the danger of air pollution is equal to the danger of water pollution.

As a concerned citizen living in Fredericton, I would like to detail the certainty of air pollution from shale gas development, and to warn that if is allowed to proceed in large regions surrounding our city, there will be a large negative impact to our quality of life here in the City of Fredericton. We need to impose a ban on shale gas at the municipal level, and then pass resolutions for the Province to do the same.

Before I give a short summary of the air pollution studies, I want to give an overview of what this issue is really about. This is about our quality of life. Quality of Life is our economic engine here in Fredericton. People are attracted to our city for its urban forest, its parks and trails, its universities, clean air, and the lack of pollution from heavy industry.

In early 2012, in addressing the doctor shortage here in Fredericton, the President of the Fredericton Chamber of Commerce, Andrew Steeves, highlighted the following: “Attracting investment, entrepreneurs, and talented professionals and skilled trades people is based largely on the quality of life and amenities a community has to offer, and excellent healthcare is at the top of the list.”

But shale gas development licenses surrounding our city in all directions is an attack on our quality of life.

Shale gas development requires the large-scale industrialization of our farmland, forests, fishing lands, and hunting lands. Distribution pipelines and compressor stations along the way must be build to transport the gas to markets. Shale gas development blankets distant communities downwind with known carcinogens & asthma-causing smog.

Fredericton will become a sink for heavier-than-air toxins such as benzene, toluene, styrene, and xylene that travel long distances from shale gas wells, the diesel emissions from truck traffic, storage tank emissions, and compressor stations.

What do all of these chemicals have in common? They are all heavier-than-air, they all cause cancer, and they all are found at toxic levels in the air downwind from shale gas operations. Benzene is one of the signature gases from drilling sites and compressor stations and this chemical has been directly linked to various blood cancers including leukemia and Non-Hodgkin’s Lymphoma.

Fredericton will have to start doing baseline air monitoring tests for VOCs, which are volatile organic compounds. We will need this data to protect ourselves from future air pollution.

The other major air pollution concern from shale gas operations is the ozone created when VOCs mix with heat and sunlight. These chemicals react with the exhaust fumes from trucks and huge generators in these operations to form ground- level ozone. This ozone can travel for over 300 kilometers before settling and accumulating in low-lying areas, such as the river valley which Fredericton is located. Saint John, New Brunswick is one of three areas in Canada that regularly exceed acceptable levels of ozone, levels established by the Canadian Council of Ministers of the Environment. Ozone can cause serious health problems in susceptible persons, especially young children and the elderly.

It is important to paint a picture of what heavier-than-air really means. As an example, carbon dioxide is heavier than air. That means it will sink to the floor. Imagine that there is a glass of water on the table and you drop a piece of dry ice in it. Dry ice is frozen carbon dioxide. This is the same chemical used for creating fog in theatres and nightclubs. The carbon dioxide gas created will then mix with water vapour and pour out of the glass, then drop down onto to the table, drop down onto the floor, and then spread out over this entire room. Now imagine that these are the volatile organic compounds and ground-level ozone, which are all heavier-than-air, and travelling long distances before settling in the valley of Fredericton.

Air pollution will be a certainty for Fredericton. New air pollution and health studies provide a clear warning. Taken individually, any of these single reports is quite troubling. But when you look at this new information together, it is truly frightening. The data confirms that if shale gas operations are allowed to proceed around Fredericton, that it will be a significant threat to our human health.

Here are some examples:

(1) Air pollution from truck traffic alone is extreme. Because of the immense amount of water used in fracking, “Each well = 1,800 to 2,600 truck drive-bys. An 8- well pad site = 14,400 to 20,800 drive-bys”. The area around Fredericton has the potential for hundreds, if not thousands, of wells to be fracked.

(2) Some areas of once pristine, rural Wyoming now have smog levels equal to Los Angeles.

(3) Oil and gas operations in the Dallas-Fort Worth region emit more smog-causing volatile organic compounds (VOCs) than all cars, trucks, buses and other mobile sources in the area combined.

(4) Texas hospital records in six counties with some of the heaviest shale gas drilling, including the Barnett Shale region, found that "children in the community ages 6-9 are three times more likely to have asthma than the average for that age group in the State of Texas."

(5) Baylor University’s results published in 2009 showed that childhood asthma rates in the Tarrant County area of the Barnett Shale were more than double the national average.

(6) The same six counties in Texas with rising rates of invasive breast cancer also have the highest count of compressors, separators, tanks and other above-ground points of emissions. Looking at the map of 254 counties in Texas, “You will notice that the counties in which you have heavier drilling activity perfectly matches the jump in breast cancer rates.”

(7) And a 3-year health study released in March 2012 “calculated higher cancer risks for residents living nearer to the wells as compared to those residing further [away]. Benzene is the major contributor to lifetime excess cancer risk from both scenarios."

(8) The final and the single-largest health threat is climate change. Our atmosphere is now moving past 400ppm carbon dioxide and our children will see carbon dioxide levels move past 550ppm and temperatures could rise by 2*C to 3*C by 2050.

RECOMMENDATION #3: Protect our homes, businesses and communities from the risk of damage due to earthquakes.

Not only are the thick deposits of glacial and alluvial sediments along the Saint John River Basin responsible for our aquifer, these same sediments amplify the ground motion of earthquakes and are responsible for larger shaking effects in the downtown area of Fredericton from distant earthquakes. The association of earthquakes with shale gas development is one more reason to exercise the precautionary principle and insist on a moratorium on any shale gas operations.

New studies are coming out each month. Authorities on earthquakes caused by shale gas development are now reporting that these earthquakes tend to be more shallow and tend to produce more damage than normal earthquakes of the same magnitude. Fredericton and the rest of the Province should exercise the precautionary principle and ban all shale gas development

RECOMMENDATION #4: Vote in progressive candidates into town and city councils that will take advantage of the huge job opportunities of the local, clean economy.

Our municipal elections across New Brunswick will be in May 2016. Let's put our local councilors, mayors, and new candidates on notice that they need to speak up and protect our air and water. Now that new Federal Government is preparing to start infrastructure funding for efficiency and clean energy projects, our towns and cities must take advantage of the huge job opportunities that this represents to our communities.

And if there is an agreement signed by world governments in Paris this December, new incentives to rapidly move away from fossil fuels will generate remarkable opportunities for job creation and local economic development. This must be the priority of our elected officials, instead of being distracted by promises of jobs with export tarsands pipelines and shale gas fracking.

And for the future health and security of our children and grandchildren, the data from climate change scientists, including NASA’s James Hansen, prove that we must leave coal and unconventionals such as shale gas in the ground.

So we really have to ask how we will attract and retain doctors when they find out Fredericton is surrounded by shale gas licenses.

They will listen to the facts more than they will listen to gas companies who impose compromising restrictions on the information they release to the public.

They will listen to the New Brunswickers whose property sales fell through because the buyers found out that the land is on, or near, shale gas lease areas. This is already happening in New Brunswick.

And they will listen to residents here in Fredericton who are voicing concerns about the health of their children, about the risk of increased asthma and cancer, about the impact on their property values, and about their quality of life.

Mayor and Council in Fredericton, and other municipalities in New Brunswick ,have an obligation to protect the health of our children, young people, and the elderly. They have an obligation to protect our air. They have an obligation to protect our quality of life.

Conclusion:

RECOMMENDATION #2: Protect the airsheds of our communities from the heavier-than-air toxic chemicals that would concentrate in low-lying valleys.

RECOMMENDATION #3: Protect our homes, businesses and communities from the risk of damage due to earthquakes.

RECOMMENDATION #4: Vote in progressive candidates into town and city councils that will take advantage of the huge job opportunities of the local, clean economy.

Therefore, I ask that the Commission on Hydraulic Fracturing recommend against lifting the moratorium on shale gas exploration and development here in New Brunswick.