Recently, a group of parties ostensibly representing the spectrum of stakeholders in Marcellus Shale — from “environmental groups” to oil companies to the non-profit funding community — announced formation of a new organization aimed at creating a set of standards for “best practices” in shale drilling, and a certification procedure that will back up the standards with what is supposed to resemble independently verified credibility. Before discussing the substance of the standards, a word must be said about the name of this new “player” in the Marcellus Shale. This organization calls itself by the unforgivable name “Center for Sustainable Shale Development” (CSSD). Let it be said at the outset — as loudly and clearly as possible:

There is NOTHING sustainable about shale gas.

When it comes to the environment, it doesn’t get much more basic than the simple precept: Thou shalt live in a sustainable way. So what does ‘sustainable’ mean? It means, very simply, that what you take from the world you arrange to have put back. A good example of sustainable technology is solar panels (photovoltaics). The energy from the sun converted to electricity by a solar panel is there again tomorrow. What about shale gas? This is exactly the opposite. The energy in the gas extracted from the ground is burned and then it’s gone. In fact, productivity of shale gas wells tanks precipitously after a shockingly short number of months. How about the enormous amount of water it takes to frack a well? This water — whatever amount of it comes back to the surface — becomes so toxic that we could reasonably call it destroyed water. Whatever water you consume in your home, it isn’t really destroyed, it stays in the water cycle. But not frack water. You could say that shale gas is actually the poster child for unsustainable energy. When CSSD has the arrogance to put the word ‘sustainable’ in its name and presume to be a consensus among shale gas stakeholders, this must be made very clear:

The very name of the organization, Center for Sustainable Shale Development, is nothing less than an Orwellian Lie. It stands the word ‘sustainable’ on its head. Intentionally. This is contemptible. Any group claiming to be an environmental group that is participating in this lie should be ashamed of itself. So, what does CSSD mean by ‘sustainable’? Evidently it means: we the people will not become so outraged at the harm caused by fracking that we will prevent them from keeping on doing it.

Now let’s look at the substance. You can read the CSSD “performance standards” here. Some parts of the CSSD “performance standards” are appalling and immoral and unacceptable: retention of the Act 13 medical gag order provisions is outrageous, for instance!

The largest driller by far here in Fayette County (in fact the only driller filing new permit applications lately) is Chevron. There are some respects in which the CSSD “performance standards” would be a step up for Chevron. Closed loop only — no frack pits — would certainly be an improvement over what Chevron is doing now. If Chevron is really serious about all this, they could start tomorrow doing away with frack pits, instead of waiting two years. Is this likely? Fat chance. From the agenda for the 3/14/2013 Fayette County Planning Commission meeting (Project Reviews):


So it appears that in Fayette County, the answer to when our top-gun driller and pioneer CSSD member Chevron will start implementing the new “performance standards” is: stay tuned. We’ll get back to you on that. They aren’t in effect now, you know.

Which brings us to the question at the heart of the matter:

Where’s Accountability?

There’s a short, not-so-sweet, simple answer to this: Accountability in the CSSD proposal is nowhere to be found. And this is why the Center for Cesstainable Shale Development needs to learn this equation:


There’s a chance some members of CSSD have seen this equation before. It’s taken from a Fayette County Public Comment on the SEAB 90 Day Report, and you can read that comment here. (On June 13, 2011, a subcommittee of the Secretary of Energy’s Advisory Board came to Washington, PA, to gather “testimony” (ably packed before the doors were supposed to be open to the public by the natural gas industry) for a mission remarkably similar to CSSD.) So we see here what the real mission of CSSD is: PR to convince the public that drilling is “safe”, but with no accountability whatsoever if a “certified” driller fails to meet the standard.

There are some things that CSSD member drillers could do to prove to us that they’re serious. Like:

• Use some of the funds you’ve raised to lobby Congress to repeal all parts of the Halliburton Loophole NOW!
  
• Legally waive all parts of the Halliburton Loophole NOW!
  
• Provide insurance to all nearby homeowners against the kind of disaster that befell the Hallowiches NOW: every well.
  
• Do away with frack pits NOW!
• Disclose all pressure anomaly data to the public NOW: every frack, every well.
• Disclose all microseismic data to the public NOW: every frack, every well.
• Acknowledge that flowback and produced water are hazardous substances NOW: every frack, every well.
• Acknowledge that flowback and produced water are likely to be radioactive NOW: every frack, every well.
• Provide MSDSs for flowback and produced water NOW: every frack, every well.
• Describe to every frack truck driver the health hazards of the load being carried NOW: every frack, every well.
• Apply for Air Quality permits for every shale gas well NOW!
  

Of course none of the measures above will satisfy those insisting on an outright fracking ban. Coopting and forestalling the outrage that will lead to a ban is exactly what CSSD is designed to do. Back to the little equation above: with no real accountability, the CSSD propaganda moves will not work.

To CSSD: Get real. “Performance standards” with no accountability are mere hype. We won’t put up with it! We need real accountability with real teeth. We need to see the teeth.