Response to the DT article: Health Department leaving oil regulation toDEQ

While I appreciate any news keeping the public aware of this topic, this article contained factual and implied misinformation that I will address with this response. A copy of this blog post will go to Patricia Bourgeois, Lenawee county health officer, Lou Schineman and Kristy Shimko, Michigan DEQ, and the Adrian city commissioners with the request to comment.

1. I do not think that the county's (or the city's) responsibility ends because a higher entity is watching upon us. If these authorities are not protecting our health and the integrity of air and water as essential resources adequately, then the county's health department(, and the city) are obliged to step in! I will provide good arguments that exactly that is needed.

2. The DEQ is NOT monitoring surface water, ground water or air quality near drilling or processing facilities. There are no baseline tests nor any follow-up tests done that could show changes through the activities of that industry. The burden of proof is once more on citizens to arrange for such tests and to do so - restricting them to only certain certified and very expensive test labs - and requiring commercial lab staff to take the samples - thus even raising costs further - which in the end leads to not many citizens being able to test their - our vital resources.

3. Most site visits and checkups (which do NOT include actual sampling!) are done by the oil and gas companies themselves. The DEQ is understaffed and instead of raising permit fees to have enough money to adequately monitor the activities of oil and gas drilling and processing, it is simply assumed that the oil and gas companies are honest and doing a good objective job in self-monitoring themselves. This is more than wishful thinking as corporations are by law required to maximize shareholder profit even at the cost of externalizing (environmental) costs - meaning having somebody else (often the government) pay the bill.

4. Lou Schineman, district manager of the DEQ’s Office of Oil, Gas and Minerals - or the staff writer Dennis Pelham, or an anonymous editor is wrong (does not know better or is misleading) when they state: "The gas being burned is basically the same as what is piped into businesses and homes and burned in furnaces, stoves, clothes dryers and water heaters". Several publications analyzing flare gases and volatiles found high concentration of toxic and cancerous BTEXs (benzene, toluene, ethylbenzene, and xylenes) and other compounds in flare gases. They partially originate from the oil and gas deposits themselves and come up in the extraction process, or are in drilling aid chemicals or site treatment chemicals. I am more than happy to produce a full list of publications and chemicals upon request. Most of these dangerous chemicals are NOT in the natural gas that we use in our houses - the gas companies are required to take these dangerous chemicals out before delivering the natural gas to the customers.

5. Kristy Shimko - or the staff writer Dennis Pelham, or an anonymous editor are wrong when they say that "the flares are burning methane and nitrogen". Methane yes (about 65% of the flammable composition), but nitrogen does not burn and is as such not flared off. While it is great that the DEQ monitors for hydrogen sulfide, that should not be the only thing they do (see above)!

6. Why is the industry permitted to flare off and WASTE a potential energy resource while POLLUTING the air for SO LONG (more than 6 months)? They should NOT be able to acquire permits to start drilling before they have the infrastructure to collect and market the gases in place!

7. If flares are located on the country-side with maybe one farmhouse close to the flare (I am idealizing here - in the Irish Hills it is often many houses, and unfortunately not only owned by the profiteer of the royalties), it is an entirely different situation within the city of Adrian with quite a few residences around the flare on Witt Farm.

8. In addition to the danger to air and water by the drilling operations and the processing facilities (tank farms), the highest chances of oil and gas spills occur during loading and unloading (e.g. into trucks) as well as during transportation (by pipelines and trucks). Both areas are to my knowledge not regulated by the DEQ - and therefore the county health department cannot depend on the DEQ to safeguard health in these error-prone sectors of the oil and gas business. Looking on the shortcomings of DOT regulations for pipelines (remember the 2010 pipeline accident near Kalamazoo, Michigan?) and trucks (several accidents involving oil trucks every year) - the nearly operational pipeline from Heritage Park (and soon other surrounding drill sites) to the Witt Farm cutting through the River Raisin floodplain, and the increased truck traffic that the central facility on Witt Farm will bring to the city once more wells are connected, the county health department (and the City of Adrian) obviously have to get and stay involved to safeguard the health of our citizens!