UPDATE (8/7/23): G2 STEM LLC has withdrawn its application for this injection well permit!

Read background information in the Pittsburgh Post-Gazette.

DCS has submitted comments to the U.S. Environmental Protection Agency opposing the issuance of a permit for an injection well in Nicholson Twp., Fayette Co., PA. In case you are wondering “Why is DCS helping in the far away southwest corner of PA?”, the answer has layers:

• Our (DCS’s) very effective start was based on solid information about what actually happens near and around gas and oil drilling. This information, to a large measure, came from generous people in western PA, including southwestern PA, who were concerned about others and often themselves injured by gas and oil drilling.
• Sub-surface faults and fractures, according to reliable sources (USGS and the Hazen and Sawyer and other NYC reports on the NY reservoirs and fracking) can travel miles – 5 miles vertically and 50 miles horizontally (Ryder). So, if injection wells were put in the Susquehanna River Basin, the injected toxic materials could conceivably travel into the Delaware River Basin, contaminating aquifers and possibly surface waters.
• We have been accused of being NIMBYs – people who only care about things that happen in their own backyard. We believe that speaking from your home is your greatest strength. I don’t know about you, but to me, my backyard is the globe – and we don’t have another.

Download the DCS comment letter as a pdf.
Download the attachments to the DCS comment letter as a pdf.

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The DCS comment letter to the EPA:

July 25, 2023

Kevin Rowsey
Source Water & UIC Section
U.S. Environmental Protection Agency Region 3
1600 John F. Kennedy Boulevard Philadelphia, PA 19103-2852

RE: Public Comment of Damascus Citizens for Sustainability Draft UIC Permit PAS2D061BFAY
G2 Stem LLC/Diversified Oil & Gas – Orville Higinbotham #1 – Nicholson Twp., Fayette County, PA

Dear Mr. Rowsey,

We respectfully submit this comment on behalf of Damascus Citizens for Sustainability (“DCS”) and its members and supporters, some of whom live in western Fayette County.

DCS strongly urges the denial of an underground injection control (“UIC”) permit for the proposed operations because G2 Stem LLC (“G2, “Applicant”) has not met its regulatory burden of showing its operations will not contaminate underground sources of drinking water (“USDWs”). Reasons for this include, inter alia, the proximity of multiple abandoned wells, including one abandoned and unplugged well that G2 failed to identify and which is located within the ¼ mile Area of Review (“AOR”); insufficient analysis and information on impacts to USDWs, particularly in light of the pressure loss during G2’s injectivity test, which suggested loss of injected fluid through fractures; a blowout that occurred within a mile of the proposed UIC operations; and the poor compliance history of Diversified Oil and Gas (the well’s owner and operator, and possibly parent company of, or related company to, G2).

DCS also urges that additional time be provided for review and comment because: 1) G2 omitted important geologic/well information that had to be gathered independently; 2) the proposed UIC operations are to occur in a state Environmental Justice area; 3) EPA failed to provide public access online to the documents listed in its administrative record index; and 4) the more DCS reviewed this application, the more problems became apparent, and it is likely that DCS has missed some items due to comment period constraints. Additional time is necessary to fully address the proposed operations and its effects on the surrounding residents and environment, which can be catastrophic and permanent. Also, even though EPA extended the time allowed to comment, the initial short commenting time precluded members of the public from hiring experts to file technical comments.

DCS’s Interests in this Matter

DCS is a 501(c)(3) non-profit, grassroots organization established in 2008 originally to protect people and watersheds from the risks associated with oil and natural gas exploration, production, processing and transportation. DCS was spurred to act based on evidence of what the oil and gas industry had done in Colorado, Texas, and the initial years of the shale gas boom in western Pennsylvania, as well as frack sand mining in the upper Midwest.

DCS is dedicated to protecting clean air, land, and water from pollution caused by fossil fuel extraction, including waste disposal from oil and gas operations. DCS works to provide individuals and communities – whether in Pennsylvania or beyond – directly or potentially threatened by fossil fuel extraction processes with the tools necessary to defend themselves.

Since DCS’s inception, DCS has been highly involved in understanding the impacts and hidden costs of, and in pushing for better regulation and oversight of, oil and natural gas extraction, production, and transportation. Such efforts have included a focus on the wastes produced at each stage and their subsequent disposal, whether to injection wells or landfills, into water sources, into the air, or onto land, including roadspreading (disposal on roads) of liquid waste from wells, (sometimes termed “brine”) and other related wastes, which can directly impact DCS members and their physical and economic health and well-being.

Continue reading the DCS comment letter here.