At a time when climate scientists are warning us that we need to move quickly to sustainable energy supplies, the Environmental Defense Fund has joined with Chevron, CONSOL Energy, EQT Corporation, and Shell in something misleadingly called the Center for Sustainable Shale Development. It seems that the real purpose of CSSD is to provide the oil and gas industry with favorable press while it ramps up fracking. At the heart of CSSD policy is a handful of flimsy, voluntary “performance standards” which will not protect the public.

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If you agree that EDF shouldn’t be in the business of “greenwashing” big oil and big gas, please sign this letter.

Mr. Fred Krupp, President
Environmental Defense Fund
257 Park Avenue South
New York, NY 10010
Dear Mr. Krupp:
Those of us concerned with charting a rational and sustainable energy policy for the United States were disheartened to see the Environmental Defense Fund (EDF) lend its name and support to an entity called the Center for Sustainable Shale Development (CSSD). The very use of the word sustainable in the name is misleading, because there is nothing sustainable about shale oil or shale gas.
These are fossil fuels, and their extraction and consumption will inevitably degrade our environment and contribute to climate change. Hydraulic fracturing, the method used to extract them, will permanently remove huge quantities of water from the hydrological cycle, pollute the air, contaminate drinking water, and release high levels of methane into the atmosphere. It should be eminently clear to everyone that an economy based on fossil fuels is unsustainable.
CSSD bills itself as a collaborative effort between “diverse interests with a common goal,” but our goals as a nation are not, and cannot, be the same as those of Chevron, CONSOL Energy, EQT Corporation, and Shell, all partners in CSSD. These corporations are interested in extracting as much shale gas and oil as possible, and at a low cost. We are interested in minimizing the extraction and consumption of fossil fuels and in facilitating a rapid transition to the real sustainable energy sources—the sun, the wind, and hydropower.
As you know, Jacobson et al. recently published a study showing that New York State could derive all its energy from renewable sources by the year 2030 using existing technologies. Clearly this model, which can be replicated in Pennsylvania and other parts of the country, calls into question the whole notion of expanding shale oil and gas extraction.
That said, we do recognize the need to limit the damage and destruction caused by ongoing extraction operations, but we do not believe that voluntary standards, approved by the industry and “greenwashed” by an environmental organization are the way to go about it. There is a better way to protect the public—it’s called regulation. The oil and gas industry is exempt from scores of state and federal laws and regulations, including key provisions of the Clean Air Act, Clean Water Act, Safe Drinking Water Act, and Comprehensive Environmental Response, Compensation, and Liability Act. Any genuine effort to limit the damage caused by oil and gas extraction begins by closing these legal and regulatory loopholes, but as far as we can tell, CSSD does not advocate this important, commonsense measure. Responsible oil and gas corporations should welcome strict regulations and enforcement with damage-proportional fines, because they will apply to the bad actors as well as good corporate citizens.
It is disappointing that the voluntary performance standards set by CSSD often fall far short of what are widely acknowledged to be best management practices. For example, Performance Standard No. 4 calls for open, double-lined pits to store flowback fluid, although closed-loop drilling systems and tank storage do a much better job of minimizing air, soil and water contamination and protecting wildlife—which, not incidentally, also enters the human food chain.
From a public health perspective, there are other glaring faults with the CSSD performance standards. Performance Standard No. 7 permits operators to limit disclosure of the chemicals they inject underground by citing trade secret protection. We simply do not believe commercial interests can be allowed to trump public health concerns regarding underground injection.
The lax nature of these standards is no doubt due in part to the fact that the partners in CSSD apparently failed to consult with the local communities that are impacted by shale extraction operations. It is doubtful that the tens of millions of Americans who live “on the shale” would approve of open waste pits or the underground injection of undisclosed toxic chemicals in the vicinity of their water wells.
The inability of CSSD to propose standards in the public interest should surprise no one. An environmental organization, with very little leverage, cannot effectively negotiate with a consortium of powerful corporations, including some of the worst actors in the industry. This same failed strategy undermined previous efforts to enact meaningful global warming legislation, and it now threatens to undermine efforts to rein in dangerous high volume hydrofracking.
While EDF is free to partner with the gas industry in CSSD, we feel it is important that the press and the public clearly understand that neither EDF nor CSSD represents the environmental and public health communities on the subject of shale oil and gas extraction.


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