When the issue is Shale Gas drilling or hydraulic fracturing, the following issues should also be considered:
Water quantity and management: how will FS manage the massive amounts of produced water. If reinjection of wastewater is involved, issues arise under the Safe Drinking Water Act as underground drinking water sources may be contaminated. Is there capacity in the area to deal with the quantities of produced water that are anticipated? Is the agency adding mitigation stipulations to adequately protect existing water rights, in particular, nearby water and stock wells?
Water Use: how will the Forest Service monitor the massive amounts of water drawn out of local streams to be used in the fracking process?
Water quality: Gas Drilling by-product water and produced water from shale gas wells is typically high in total dissolved solids (TDS), minerals and salts. Have FS, if the water is to be stored in reservoirs or dumped onto the ground, provided baseline information for existing water quality? Have they assessed the impacts of high saline water on soils, vegetation, fisheries, domestic livestock and wildlife?
For Hydraulic Fracturing: Has the agency considered the potential risks to groundwater of contamination?
For Hydraulic Fracturing: Has the agency considered the risk of spills of frack fluids?
For Hydraulic Fracturing: If the agency will allow produced water to be stored in pits or impoundments, has the agency considered the risks of spills and flooding? Has the agency considered the potential harm to species in the area that might drink from, land in, or otherwise come into contact with the produced water in pits?
For fracking: Has the agency adequately assessed and modeled the time for underground aquifers to recharge and replenish?
These are but a few of the major impacts associated with hydraulic fracturing and gas drilling and it is important to raise the issues that are germane to the project being proposed. The purpose of NEPA, of course, is to study, understand, disclose and assess mitigation alternatives for all of these impacts before the project is approved, and not years later, when the environmental impacts will most likely be irreversible.
Specific Issues to Raise: